Implementation advanced planning document

IMPLEMENTATION
ADVANCED PLANNING DOCUMENT
October 13, 2010
Version 1.0
Submitted by the
Oklahoma Health Care Authority
on behalf of the State of Oklahoma
With technical assistance provided by:
6263 North Scottsdale Road
Scottsdale, AZ 85250
(480) 423-8184
www.cognosante.com
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 13,2010
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TABLE OF CONTENTS
1 EXECUTIVE SUMMARY.....................................................................................................1
1.1 Purpose............................................................................................................................1
2 THE IMPLEMENTATION ADVANCE PLANNING DOCUMENT (IAPD)............................2
2.1 Preparation for the IAPD...................................................................................................2
2.1.1 As Is HIT Landscape Assessments................................................................................2
2.1.2 To Be Vision...................................................................................................................3
2.1.3 Actions to Implement Oklahoma EHR Provider Incentive Payment Program................3
2.1.4 Audit Strategy.................................................................................................................4
2.1.5 HIT Roadmap.................................................................................................................4
3 STATEMENT OF NEEDS AND OBJECTIVES...................................................................5
3.1 Roadmap Projects.............................................................................................................5
3.1.1 Federally Mandated Projects..........................................................................................5
3.1.2 OHCA Priorities..............................................................................................................5
3.1.3 Enhancements...............................................................................................................5
3.2 Needs...............................................................................................................................7
3.3 MITA SS-A......................................................................................................................10
3.3.1 Executive Goals and Objectives...................................................................................11
3.3.2 Needs Relating to State Self-Assessment...................................................................15
4 NATURE AND SCOPE......................................................................................................18
4.1 Planning.........................................................................................................................18
4.1.1 System Modification Requirements..............................................................................18
4.1.1.1 Develop and Implement System Changes................................................................19
4.1.2 Operations....................................................................................................................19
4.1.2.1 Communication.........................................................................................................19
4.1.2.2 Provider Outreach and Education Plans...................................................................19
4.1.2.3 Provider Eligibility and Enrollment in EHR Incentive Payment Program...................21
4.1.2.4 Provider Attestation...................................................................................................21
4.1.2.5 Provider Payments....................................................................................................21
4.1.2.6 Provider Payment Monitoring....................................................................................21
4.1.2.7 EHR Incentive Payment Reporting............................................................................21
5 STATEMENT OF ALTERNATIVE CONSIDERATIONS...................................................22
5.1 Description of Alternatives..............................................................................................22
6 STATE RESOURCES........................................................................................................23
6.1 Medicaid Structure..........................................................................................................23
6.2 OHCA Administration......................................................................................................23
6.2.1 OHCA Key Staff...........................................................................................................25
6.3 Administrative Costs.......................................................................................................26
7 SCOPE OF ACTIVITIES AND PROJECT METHODOLOGY............................................27
7.1 Project Approach.............................................................................................................27
7.2 Tasks..............................................................................................................................27
7.2.1 Tasks Completed to Date.............................................................................................27 Oklahoma Health Care Authority
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7.2.2 Tasks Underway at This Time......................................................................................27
7.2.3 Tasks to Be Undertaken...............................................................................................27
7.2.4 Activity Schedule for the Project...................................................................................28
8 PROPOSED BUDGET.......................................................................................................29
8.1 Overview........................................................................................................................29
8.2 Budget by State and Federal Share................................................................................30
9 STATEMENTS OF ASSURANCES...................................................................................34
10 CONCLUSION...................................................................................................................36
APPENDIX A: ACRONYMS.......................................................................................................37
APPENDIX B: PROJECT PLAN................................................................................................39
APPENDIX C: MITA SS-A UPDATE..........................................................................................40
LIST OF FIGURES
Figure 1 Percentage of Providers Reporting EHR/EMR by Group...............................................2
Figure 2 To Be Roadmap..............................................................................................................6
LIST OF TABLES
Table 1 Additional Resources to Support EHR Incentive Payment Program...............................7
Table 2 Executive Guiding Principles and Objectives.................................................................11
Table 3 System Modification under Umbrella CO 10557............................................................18
Table 4 Estimated Costs to Administer EHR Provider Incentive Payment Program...................26
Table 5 Proposed Activity Schedule...........................................................................................28
Table 6 Estimated Quarterly Costs to Administer Program – Federal........................................30
Table 7 Estimated Quarterly Costs to Administer Program – State............................................31
Table 8 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by Calendar Year............................................................................................................................32
Table 9 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by State Fiscal Year.................................................................................................................................32
Table 10 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by Federal Fiscal Year.....................................................................................................................32
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 13,2010
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1
EXECUTIVE SUMMARY
1.1
Purpose
The section provides a high-level executive summary for the request by the State of Oklahoma for enhanced federal financial participation (FFP) from the CMS in accordance with Federal regulations. This request supports the administration of the EHR Incentive Payment Program and the administrative efforts required to support the SMHP Implementation activities.
The Oklahoma Health Care Authority (OHCA) is the single state agency that administers the Oklahoma Medicaid program. The State of Oklahoma has elected to participate in the Electronic Health Record Provider Incentive Payment Program funded through CMS. This Implementation Advance Planning Document (IAPD) is a request by the OHCA on behalf of the State of Oklahoma for enhanced federal financial participation (FFP) from the Centers for Medicare & Medicaid Services (CMS) in accordance with Federal regulations1. The State Medicaid Health Information Technology Plan (SMHP) was submitted for consideration by CMS on August 3, 2010, and approval received on September 3, 2010.
This request supports the first phase of the state’s participation in the development and expansion of the use of Electronic Health Records (EHR) and collaboration among state entities in a Health Information Exchange (HIE) network. In the first phase, the OHCA will implement the system changes necessary to support the Oklahoma EHR Provider Incentive Payment Program as well as the administrative supports necessary for implementation and operation of this program.
Effective September 3, 2010, the OHCA will close the Planning Advance Planning Document (P-APD) submitted to CMS in December 2009 and open the IAPD, adding chapters to this IAPD to request funding for future projects as details of the projects become known.
The OHCA anticipates that the system changes will be completed, tested, and implemented by January 1, 2011 in preparation for provider registration beginning in January 2011 and subsequent eligible provider payments.
The OHCA requests on behalf of the State of Oklahoma $3,742,012.34 to support the Oklahoma EHR Provider Incentive Payment Program implementation costs, including State staff, contractor costs, and expenses associated with provider training and outreach. The State anticipates provider incentive payments will be made to approximately 1,450 eligible professionals (EPs) and 130 hospitals (which includes six Indian Health Services (IHS) hospital facilities) in calendar year 2011, totaling $48,251,298. This includes an estimated $17,438,798 to eligible hospitals and $30,812,500 to EPs. Related MMIS modifications are reimbursable under the Section 4201 of the American Recovery and Reinvestment Act (ARRA).
As the program is further defined by CMS, and tools are refined by the Office of the National Coordinator of Health Information Technology (ONC), the State’s SMHP will be updated with changes in policy and process, and this IAPD will be updated to include costs as necessary. The Oklahoma Health Information Exchange (OKHIE) Strategic and Operations Plans are not approved and the SMHP must be aligned following their approval. At a minimum, the SMHP will be updated annually.
1 Part 11 of the State Medicaid Manual (SMM) & 42 CFR subpart C - 433.112(a) Oklahoma Health Care Authority
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THE IMPLEMENTATION ADVANCE PLANNING DOCUMENT (IAPD)
2.1
Preparation for the IAPD
This section will describe the activities supporting the development of the IAPD; including the development and submission of the SMHP, as well as the visioning, selection and planning for the set of initiatives described in this request.
This IAPD has been developed following the submission of the SMHP on August 3, 2010. The Health Information Technology (HIT) P-APD outlined the tasks and activities necessary to complete the SMHP and IAPD to support the Oklahoma EHR Provider Incentive Payment Program. Excerpts from the SMHP are provided here to inform on the results of the SMHP planning activities. Readers should refer to the SMHP document for detailed information.
The OHCA conducted assessments, analysis, and planning activities in the following five areas as required by CMS during the preparation of the SMHP. High-level results are as follows.
2.1.1
As Is HIT Landscape Assessments
The OHCA has conducted the As Is HIT Landscape Assessments for professionals, hospitals, Federally Qualified Health Centers (FQHCs)/Rural Health Centers (RHCs), and Indian Health Services/Tribal Facilities/Urban Indian Clinics (I/T/U). Results were shared with OKHIE, Oklahoma Foundation of Medical Quality Health Information Technology (OFMQHIT), the Oklahoma Hospital Association (OHA), Oklahoma State Medical Association (OSMA), Oklahoma Office of State Finance (OSF), and Oklahoma State University Center for Rural Health (OSUCRH). OKHIE is currently conducting an environmental scan for networks and these results will be shared with the OHCA when available. The methodology, survey questions, participants, timeline, and results are available in the SMHP. The results of overall EHR adoption across the different provider groups targeted in the scans are shown in Figure 1 Percentage of Providers Reporting EHR/EMR by Group. “Presumed eligible” providers were those that self-reported meeting the patient volume requirements established in the proposed rule and were enrolled in an eligible provider type. Page 2
Figure 1 Percentage of Providers Reporting EHR/EMR by Group Oklahoma Health Care Authority
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There were a number of initiatives identified that impact SoonerCare members, including several quality improvement initiatives; use of telemedicine to improve access to care for members in rural or underserved areas; electronic eligibility and claims transactions; ePrescribe capabilities, clinical lab ordering and results delivery; and public health reporting.
Additionally, the OHCA collaborated with stakeholders and conducted a comprehensive statewide assessment of HIT assets available to determine how these may be leveraged in the future to improve care coordination of SoonerCare Members. Stakeholders collaborating in these efforts include: Health Information Infrastructure Advisory Board (HIIAB), OKHIE, Broadband grantee, Beacon Communities grantee, OFMQHIT, OSMA, OHA, and other stakeholders.
Broadband penetration across Oklahoma is a barrier to health information exchange with providers in rural areas. There are numerous federal funding agencies for broadband efforts and Oklahoma stakeholders have applied for and received grants under several funding sources.
2.1.2
To Be Vision
The OHCA’s vision for the future anticipates improvements in health outcomes, clinical quality, and efficiency in multiple physical and behavioral healthcare management environments with increased usage and interoperability of EHR systems. Best practices and trends in direct care and care coordination efforts can be identified by expanding reporting capabilities and evaluating outcomes data. Potential and actual cost impact can be calculated to guide further program development. Utilization review endeavors can be enhanced from both pre-payment and post payment perspectives. Through developments in data exchange through HIEs, provider access to data will further enhance care coordination opportunities, eliminate duplication of service, and foster identification of appropriate levels of care. Similarly, the OHCA, on behalf of SoonerCare members, will be able to more effectively identify serious quality of care issues, gaps in care, member compliance issues, and member behavior trends in areas such as Emergency Room (ER) utilization.
The OKHIE Strategic and Operational Plans are not approved and a comprehensive vision for statewide HIT/HIE is not available at this time. Thus, the OHCA will update its SMHP after further collaboration with OKHIE and development of these statewide plans. The OHCA plans to align its vision with the statewide vision once approved.
2.1.3
Actions to Implement Oklahoma EHR Provider Incentive Payment Program
The OHCA business areas reviewed the regulatory requirements for submission of the SMHP published in the Final Rule at §495.332 and in CMS guidance for developing the SMHP published on April 29, 2010. Work groups were formed in alignment with the OHCA’s current concept of operations. These work groups then reviewed each business process that has been affected or will be implemented to develop a concept of operations for the Oklahoma EHR Incentive Payment Program. Where feasible, the approach adopted was to integrate the Oklahoma EHR Incentive Payment Program business process into the OHCA’s corresponding standard Medicaid Information Technology Architecture (MITA) business processes. Oklahoma Health Care Authority
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2.1.4
Audit Strategy
The OHCA Program Integrity (PI) adheres to Government Auditing Standards (The Yellow Book) developed and maintained by the Government Accountability Office (GAO). The OHCA PI staff in the Policy, Planning, and Integrity Division have been involved in the review of the regulatory requirements and the Final Rule, and participated in numerous CMS guidance opportunities (e.g., webinars, conference calls, and meetings). Wherever possible, the OHCA PI staff will work to incorporate the post-payment audits needed to support the Oklahoma Provider Incentive Payment Program into ongoing, regular provider audits. Further, the OHCA operations will engage in prepayment evaluation of provider attestation material and related documents to ensure the provider’s eligibility for the program. By coordinating pre- and post-payment activities, the OHCA will minimize the risk of overpayment or fraudulent payments under this program. The SMHP in Section 5.1.2.1 describes in detail the processes supporting the necessary internal and external controls, and the OHCA audit strategy.
2.1.5
HIT Roadmap
The SMHP includes a description of the modifications to the MITA Roadmap to include HIT and Provider Incentive Payment Program activities. The April 1, 2010 submission of the HIT Roadmap with the MITA State Self-Assessment (SS-A) anticipated HIT-related activities. These activities were further developed in the SMHP to show the HIT Roadmap for near-term projects.
The OHCA is deferring some of its longer-term planning and benchmark development for HIT/HIE awaiting the OKHIE to complete its Strategic and Operational Plans. Separate IAPDs will be submitted to construct a bridge from the MMIS to the OKHIE and to procure a Meaningful Use Data Warehouse. The OHCA dialog with the HIIAB, Broadband grantee, and Beacon Communities grantee is underway. When details of these projects are fully understood, including a timeline for projects, the SMHP will be updated and separate IAPD requests for funding will be submitted. Oklahoma Health Care Authority
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3
STATEMENT OF NEEDS AND OBJECTIVES
This section will describe the projects and administrative activities that are covered in the IAPD.
Medicaid Management Information System (MMIS) enhancements are required to support administration of the Oklahoma EHR Provider Incentive Payment Program. The OHCA plans to implement the Incentive Payment Program in January 2011.
3.1
Roadmap Projects
Projects listed on the HIT Roadmap are grouped into three different categories for the purpose of identifying their origin.
3.1.1
Federally Mandated Projects
Federally mandated projects are not optional and must be completed as required by legislation, a rule, or regulation. These projects have pre-defined implementation dates dictated by the applicable regulatory body.
3.1.2
OHCA Priorities
Projects identified by Executive Staff as an OHCA priority must be completed to better assist agency staff in performing their daily business activities and ensure that programs and services respond to the needs of members by providing necessary benefits and improved health care access.
3.1.3
Enhancements
Enhancements originated from an initial list of over 500 requirements identified by the business users as functionality that, if implemented, would improve current business processes. The requirements contained a myriad of improvement techniques, including increased automation, elimination of duplicative processes, enhanced data mining and metrics, improved communication and correspondence tracking, among many others. The initial list of 500 plus requirements went through several rounds of consolidation. After final consolidation, requirements were grouped into 39 different categories. The categories were then prioritized and from the initial list of 39, 10 were identified for inclusion within the Roadmap.
The complete list of Roadmap projects including enhancements can be viewed in Figure 2 To Be Roadmap below. This HIT Roadmap will be updated to further define the ARRA/HIE/EHR projects and timeline in future chapters to this IAPD as the specifics of the projects are known.
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Figure 2 To Be Roadmap
X12 5010 and NCPDP TransactionsICD-10 PlanningICD-10 ImplementationARRA/HIE/EHRHealthcare ReformSelf-Directed Services (MFP)Online EnrollmentInsure OK & CHIPRAMMIS Documentation UpdatesRegression Testing GeneratorProgram IntegrityCTI and Call TrackingDocument Mngmnt/ImagingLetter Generation/CorrespndceMedical Policy Review & Eval.Claims - Rules EngineClaims - Resolutions WorkflowSecure Provider PortalSecure Member PortalFinance2017Phase IIIPhase IIab2016Phase IOHCA Priorities2014201220112010Project PhasesEnhancements2013Mandates2009Calendar YearProjects2015Issue RFPAwardHardware TRANSITIONCurrent FA Operations End TakeoverDDI Continuing Operations + DDI1 yr optionContinuing Operations Page 6
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
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All MMIS enhancements, excluding Oklahoma Provider Incentive Payment Program system changes are included within the current RFP, and were funded in a separate IAPD request submitted to CMS on April 1, 2010.
3.2
Needs
This section will describe the needs the OHCA has identified that must be fulfilled in order to support the EHR Incentive Payment program administration as described in the SMHP document.
The OHCA has identified the following needs that must be fulfilled in order to support the EHR Incentive Payment Program administration: These enhancements are described in the Oklahoma SMHP submitted to CMS on August 3, 2010. Generally, the enhancements include:
1.
Modifications to the Oklahoma Provider Portal – Electronic Provider Enrollment (EPE) to allow providers to attest to their eligibility for the EHR Incentive payment.
2.
An interface to the National Level Registry (NLR) to exchange information regarding the provider registration information, including the National Provider Identifier (NPI) and Tax payer Identification Number (TIN) numbers used to register with CMS and the amount and timing of the incentive payment. The database will inform the OHCA in the event the provider has registered for incentive programs in any other states and/or the Medicare Program.
3.
Modifications to the MMIS Financial Module to uniquely account for the incentive payments by adding new accounting codes, updating reports, and developing a panel to support the calculation of provider incentive payment amounts.
4.
Modifications to the Management and Administrative Reporting System (MARS) to accommodate required federal and internal reporting of the incentive payments as well as program administration costs.
The OHCA has thoroughly reviewed and planned for adequate staff to meet Oklahoma EHR Provider Incentive Payment Program objectives. Oklahoma plans to administer the program by leveraging existing OHCA support units (see Section 4.1.10), as well as supplement existing State staff with new positions as identified in Table 1 Additional Resources to Support EHR Incentive Payment Program, which includes the position description and responsibilities for new staff supporting the program.
Table 1 Additional Resources to Support EHR Incentive Payment Program
Positions Needed
Position
Description
Responsibilities
Annual Salary
1
Data Processing/
Planning Specialist
Conducts system and data analysis, develops requirements, assists in validation of system design and test results.
Assist senior analysts with healthcare interoperability projects such as data sharing with the statewide Health Information Exchange , system modifications necessary to support EHR incentive payments, data warehouse for meaningful use criteria and reporting, telemedicine and other interoperability efforts of the
$47,739 Oklahoma Health Care Authority
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October 15, 2010
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Positions
Needed
Position Description Responsibilities Annual
Salary
agency.
2
Financial Information Analyst
Plans, directs, and coordinates EHR incentive payment program fiscal operations and financial accounting functions. Develops accounting systems and procedures for recording revenues and expenditures. In addition to the current Financial Information analyst position duties
The OHCA will begin making EHR incentive payments to EPs and EPs in January 2011. These payments will need to be managed separately from all other payments to providers. Close coordination with CMS is required to track the payments for accuracy and adherence to policy. Eligible providers may select to begin the program in different years and/or not participate in consecutive years creating a complex payment structure which will require new monitoring methods by Finance to ensure payments are made correctly. A different payment structure is required for payments to hospitals.
$60,846
1
Provider Education Specialist
Provide direct and indirect support for the health care community. Aid eligible providers and hospitals with EHR incentive payment questions. Provide outreach and education to the healthcare community.
EHR incentive payment program requirements are complex. The OHCA will need additional staff to answer questions/calls regarding EHR incentive payments. Additional SoonerCare representation will be required at provider association meetings, individual facilities and the regional extension centers. Additional SoonerCare provider training sessions will be needed to support the program.
$46,850
2
EDP Auditors
Conduct onsite audits of provider and facility EHR systems to ensure compliance with Federally defined meaningful use criteria. Provide technical support to providers and other OHCA auditors on policy issues, such as
Electronic Data Program auditors review systems for compliance. The auditing requirements for the EHR incentive payment program are complex and require the ability to understand how “the EHR system” works internally. An auditor is needed to review “the EHR system” to augment the
$71,119 Oklahoma Health Care Authority
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Positions
Needed
Position Description Responsibilities Annual
Salary
electronic signature verification.
OHCA auditing staff when reviewing meaningful use compliance.
2
Legal Policy Analyst
Reviews documentation submitted to support provider attestation prior to payment approval.
The Legal Policy Analysts will assist in drafting new Oklahoma EHR Provider Incentive Payment program sections for the Provider Manual, review and draft responses to provider payment appeals, and provide interpretation of program rules upon request from the OHCA, Fiscal Agent and/or providers.
$71,119
1
Network
Administrator
Supports provider request for assistance by documenting software issues, and providing hands-on troubleshooting with provider to resolve data format issues.
Receive telephone calls from providers and attempt to resolve computer/software problems. Complete trouble tickets and compile weekly management reports. Provide technical support to providers.
$46,850
1
Network Administrator
Supports network computers, servers, and printers to ensure connectivity to providers and other external stakeholders.
Monitor network functioning for optimal levels; troubleshoot issues with connectivity; monitor security of HIE data exchange. Review system logs and investigate security incidents, etc.
$60,846
1
DP Analyst /
Planning Specialist IV
Analyzes agency policy and plans for application systems, operating systems, and data processing personnel. Makes recommendations to supervisors and agency management on proposed enhancements to agency policy and plans, with particular attention to potential budgetary impact.
Manage the implementation of the EHR Incentive payments, meaningful use, connection to the HIE, EHR implementation from a technical perspective for the OHCA.
$60,846
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
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3.3
MITA SS-A
This section will describe the process used to update the Oklahoma MITA SS-A and the business areas, capabilities and technology improvements that result.
The Oklahoma MITA SS-A updates are required due to the additional responsibilities to administer the EHR Provider Incentive Program. The OHCA used a process similar to the process used to develop the original MITA SS-A. Subject matter experts were consulted regarding the business processes needed to support the EHR Provider Incentive Payment Program. These processes were compared to the MITA Business Processes and refined as needed to reflect the work patterns applied in Oklahoma. The result of this assessment was that most business processes would not be impacted by the new program. As a result, the MITA capabilities and maturity levels were not changed.
The MITA assessment did, however, identify several system updates that have occurred since the MITA SS-A was conducted in 2009, resulting in a small number of both capability and maturity level changes to the original MITA SS-A, and those changes are reflected within this MITA SS-A update. In addition, two new business processes were added reflecting the need to implement EHR Incentive Payment provider attestations and provider communication coordination with the Regional Extension Center (REC).
In addition, the OHCA has recently completed the implementation of a web-based Electronic Provider Enrollment (EPE) system. The system extends the ability to providers to manage their own enrollment and demographic information online. This online system will be further enhanced to collect and store the Oklahoma EHR Provider Incentive Payment Program attestation information. Oklahoma Health Care Authority
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3.3.1
Executive Goals and Objectives
This section will describe the high level visioning activities and updates needed to align the MITA SS-A with the HIE, HIT efforts and the EHR Incentive Payment program.
Table 2 Executive Guiding Principles and Objectives
MITA Goal
OK Guiding Principle
Objective/Actions
Integrated Call Center – This will provide enhanced call routing capabilities and the integration and availability of call center data to provide operational efficiency and flexibility across all the OHCA call centers.
Promote efficient and effective data sharing to meet stakeholder needs.
Document Management – Integration of the COLD imaging system with the MMIS for improved access to information and operational efficiency.
Letter Generation – Implement a flexible and configurable system component to improve operational efficiency and enhance member and provider communication.
Enhance and introduce up-to-date management information and communication systems through the MMIS Reprocurement project.
Medical Care Management (Atlantes) – Enhancement of the Atlantes Case Management system and further integration with the MMIS will allow a broader spectrum of the OHCA staff to utilize the system more effectively.
Promote reusable components and modularity.
Claims Processing – Implementation and integration of the existing Business Rules Engine into the MMIS for enhanced claims processing.
Secure Provider Portal – This enhancement will allow providers real-time online access to view and change their account information, saving the OHCA significant staff time in data entry and phone inquiries.
Provider attestation and EHR Incentive Payment Program Participation will be captured using the portal as well.
Integration and Interoperability
Promote efficient and effective data sharing to meet stakeholder needs.
General System Functionality – Enhancement of Data Warehouse capabilities (Data Cubes) for analyzing and reporting of data. It will also include the creation of Dashboards for management decision-making and access to data by the public.
Drug Rebate – Automate the process and provide online access for invoices and payments to suppliers.
Integration and Interoperability
Promote efficient and effective data sharing to meet stakeholder needs.
Drug Utilization Review – Reference data file enhancement. Oklahoma Health Care Authority
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MITA Goal OK Guiding Principle Objective/Actions
Asset Verification – Electronic data exchange with financial institutions for asset verification of Dual Eligible’s.
Provide a beneficiary-centric focus.
Online Enrollment – Implement an online enrollment and eligibility system that will integrate with the MMIS to provide enhanced accessibility and eligibility and benefit determination for members.
Oklahoma Health Information Organization – Through participation in this statewide initiative, the OHCA commits to promote a comprehensive approach to accelerating the exchange of health information by involving providers and consumers, establishing State agency trust, developing sustainable funding sources, providing capable business services and operations, developing technical capabilities and consulting with State officials.
Identify, qualify, and manage a cost-effective, efficient, and flexible SoonerCare program.
Online Enrollment – Implement an online enrollment and eligibility system that will integrate with the MMIS to provide flexibility in response to SoonerCare program and policy changes.
Adopt data and industry standards.
HIPAA 5010 and ICD-10 – The system enhancements to comply with these federally mandated data formats will be included in the MMIS Reprocurement project.
Support integration of clinical and administrative data.
Medical Artificial Intelligence (MEDai) Health Management – The integration of MEDai with the SoonerCare Secure Site will allow providers access to information about the illness burden of the SoonerCare members they treat. This information is critical to providers at the point of care to improve health outcomes for SoonerCare members.
Flexibility to respond rapidly to change
Promote secure data exchange.
Health Information Exchange (HIE) – Implementation of the initial infrastructure to provide the capability to exchange health information between State entities and the public.
Secure Member Portal – Implement a portal to provide members the ability to view and manage their information and eventually the capability for Personal Health Records.
Flexibility to respond rapidly to change
Promote secure data exchange.
Electronic Provider Referral – Online access to information for providers to refer members to a specialist. Oklahoma Health Care Authority
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MITA Goal OK Guiding Principle Objective/Actions
Program Integrity (PI) – The PI system will integrate new technologies with fraud detection and case tracking systems to improve the effectiveness and efficiency of fraud and abuse investigations.
Sustain and maximize available funds.
Medical Policy Review – Review of reimbursement rates and methodologies to ensure that provider payments are consistent with efficiency, economy, and quality of care.
Claims Resolution – Implementation of automated workflow for MMIS claims resolution.
Simplify the claim process, through collaboration with providers.
Claims Processing – Implementation and integration of the Business Rules Engine into the MMIS to provide efficiency and flexibility in the processing of claims.
Enterprise view to align technology and business needs
Break down artificial boundaries between systems, geography, and funding.
Insure OK and Insure Tulsa – Expansion of the Insure Oklahoma premium assistance program to provide insurance coverage for the uninsured.
Insure Oklahoma (IO) – Expansion of the Insure Oklahoma premium assistance program to provide insurance coverage for the uninsured.
Seek to greatly improve the status of health care across the State.
SoonerCare – Expansion of the SoonerCare program for 19- and 20-year olds.
Data that supports analysis and decision-making
Ensure accuracy and correctness of payments.
Program Integrity (PI) – Implement a comprehensive PI system consisting of a Fraud and Abuse Component, a Medical SURS Component, a Case Tracking System, and Data Management for the OHCA Program Integrity & Accountability Unit.
The Insure Oklahoma premium assistance system enhancement will include an electronic management system for financial transactions to and from multiple sources, such as premium receipts, invoices, accounts receivable, accounts payable, state and federal donations, and commissions.
Medical Policy – Review and implementation of enhanced edit and audit functions for MMIS claims processing.
Data that supports analysis and decision-making
Ensure accuracy and correctness of payments.
Finance – Enhancements to the Financial system for management of payments and adjustments and reporting, including provider incentive payments. Oklahoma Health Care Authority
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MITA Goal OK Guiding Principle Objective/Actions
Improve the effectiveness and efficiency of the delivery of medical services.
The Emergency Room (ER) Diversion Grant will help the OHCA develop a program to access a full array of primary and preventative health care for Oklahoma County SoonerCare members. Specifically, this project addresses the overuse of hospital emergency room use.
Maximize revenue by containing costs, eliminating duplication, and using all sources of funds.
The OHCA plans to explore the opportunities that exist to better serve Oklahoma’s Dual Eligible population and to capitalize on the expertise of other states, as well as utilize other resources such as the Center for Health Care Strategies, that might assist the OHCA to develop a care coordination plan for Oklahoma’s Dual Eligibles.
Performance measurement for accountability and planning
Provide continuous improvement/utilization review by evaluating service outcomes, program costs, and provider participation to maximize and effectively manage resources.
Plans to review and make recommendations and/or implement changes in payment methodologies and reimbursements in order to ensure fair compensation to providers.
Coordinate with Public Health and other partners to improve overall health
Attract and maintain a strong network of service providers by continuously evaluating and implementing programs that strengthen the reimbursement process.
Self-Directed Services – The Opportunities for Living Life (OLL) action plans continue to describe the OHCA’s many partnerships with other agencies, providers, and advocates to develop partnerships to improve access to long-term support services, and provide for better choice and control for the OHCA’s aging population.
Coordinate with Public Health and other partners to improve overall health
The OHCA is committed to developing a health care partnership with policy makers, beneficiaries, providers, and stakeholders from the community to provide maximum health care benefits to qualified individuals through innovative and cost-effective programs.
Research in the Health Care Infrastructure in local communities within the State of Oklahoma is intended to allow various stakeholders including, but not limited to local community leaders, etc., to see both the small- and large-scale pictures of the existing health care infrastructure within their communities. It is hoped that this research may help community leaders make informed decisions about future planning. It is expected that at the conclusion of the research a final report will be prepared and distributed to stakeholders across the State. Oklahoma Health Care Authority
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MITA Goal OK Guiding Principle Objective/Actions
The OHCA has implemented a system called the Health Management Program (HMP) that targets members with chronic conditions who have been identified by predictive modeling to have a high risk of incurring significant medical cost.
The HMP provides patient education and care management services to participants. The HMP also develops provider collaboration focused on holistic health management and evidence-based guidelines, and one-on-one practice facilitation for some primary care providers provided by the OHCA’s contractor, the Iowa Foundation for Medical Care.
3.3.2
Needs Relating to State Self-Assessment
This section will describe the business areas impacted by the EHR Incentive Payment Program Implementation and Administration.
In accordance with 42 CFR §495.338 outlining the submission of IAPD documents to CMS for consideration, the OHCA conducted a review of the MITA SS-A previously developed in June 2009 and submitted with the IAPD and RFP on April 1, 2010.
The findings of this review are identified in this section and presented in detail in Appendix C.
Member Management – The Member Management business area is a collection of business processes involved in communication between the Medicaid agency and the prospective or enrolled member and actions that the agency takes on behalf of the member. The goal for this business area is to improve healthcare outcomes and raise the level of consumer satisfaction.
Opportunities will develop as the OKHIE is put into place and eligible providers implement certified EHR technology to improve member management business processes and exchange of individual patient clinical data for treatment, payment, and health plan operations. Through compliance with meaningful use objectives, members will realize improved access to their health care information. Through ePrescribe capabilities, providers will submit prescriptions to pharmacies, allowing members more timely access to necessary medications.
Provider Management – MITA defines the Provider Management business area as a collection of seven business processes that focus on recruiting potential providers, supporting the needs of the provider population, maintaining information on the provider, and communicating with the provider community. The goal of this business area is to maintain a robust provider network that meets the needs of both the member and provider communities and allows the State Medicaid agency to monitor and reward provider performance and improve health care outcomes.
Improvements in Provider Management business processes include online enrollment in the Oklahoma EHR Provider Incentive Payment Program (including online attestation, electronic signature), and allowing providers to self-manage demographic and participation information. In addition, as the OKHIE and the Meaningful Use data store are developed, providers will be able to report Meaningful Use measures and have access to clinical information that will improve outcomes and decision-making for their patients. A collaborative approach continues to inform eligible professionals about the Oklahoma Provider Incentive Payment Program and ongoing communications and collaboration with stakeholders (e.g., HIE, OSMA, OHA, FQHCs/RHCs, I/T/U). Oklahoma Health Care Authority
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Contractor Management – The Contractor Management business area accommodates states that have managed care contracts or a variety of outsourced contracts. The Contractor Management business area has a common focus (e.g., manage outsourced contracts), owns and uses a specific set of data (e.g., information about the contractor or the contract), and uses business processes that have a common purpose (e.g., solicitation, procurement, award, monitoring, management, and closeout of a variety of contract types).
The OHCA has no managed care contracts; thus, there are no needs identified at this time.
Operations Management – The Operations Management business area includes operations that support the adjudication of claims and encounters, payments to providers, other agencies, insurers, Medicare premiums, and support the receipt of payments from other insurers, providers, and member premiums. This business area focuses on adjudication of claims and encounters, payments, and receivables and “owns” all information associated with service payment and receivables.
The OHCA will use their standard MITA business processes for making provider incentive payments, Federal Financial Participation (FFP) drawdown, and recoupment of any payment found to be in error.
Program Management – The Program Management business area houses the strategic planning, policymaking, monitoring, and oversight activities of the agency. These activities depend heavily on access to timely and accurate data and the use of analytical tools. This business area uses a specific set of data (e.g., information about the benefit plans covered, services rendered, expenditures, performance outcomes, and goals and objectives) and contains business processes that have a common purpose (e.g., managing the Medicaid program to achieve the agency’s goals and objectives, such as by meeting budget objectives, improving customer satisfaction, and improving quality and health outcomes).
The OHCA will be developing program policy for the Oklahoma EHR Provider Incentive Program. MMIS enhancements are required to perform accounting functions, support generation of payments, FFP drawdown, and develop new CMS reports required for tracking and reporting on American Recovery and Reinvestment Act (ARRA) funds expended. As OKHIE determines its plans for the future, opportunities will develop to monitor meaningful use measures and provider performance outcomes.
Business Relationship Management – Business Relationship Management refers to the standards for interoperability between the State Medicaid agency and its partners. It contains business processes that have a common purpose (e.g., establish the interagency service agreement, identify the types of information to be exchanged, identify security and privacy requirements, define communication protocol, and oversee the transfer of information).
The OHCA plans to implement contract changes to data exchange agreements with other states; revise trading partner agreements to ensure security and privacy of data exchanged through the statewide HIE, and require exchange of laboratory data for Public Health statewide initiatives.
Program Integrity Management – The Program Integrity business area incorporates those business activities that focus on program compliance (e.g., auditing and tracking medical Oklahoma Health Care Authority
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necessity and appropriateness of care and quality of care, fraud and abuse, erroneous payments, and administrative abuses).
The OHCA will use their standard MITA business processes for auditing and tracking provider incentive payments. There will be availability of clinical data and an increased ability to measure health outcomes and compare between providers best practices for treatment of specific diagnoses. Care Management will be enhanced by the availability of clinical measurement data. The OHCA will leverage the capabilities provided by the planned OKHIE in conjunction with the State system capabilities to review benchmarks and objectives to enhance the administration of the Medicaid program and improve health care delivery and outcomes in Oklahoma.
Care Management – Care Management collects information about the needs of the individual member, plan of treatment, targeted outcomes, and the individual’s health status. It also contains business processes that have a common purpose (e.g., identify clients with special needs, assess needs, develop treatment plan, monitor and manage the plan, and report outcomes).
The OHCA will leverage the clinical data available through the HIE for use in prior authorization and Health Management Program (HMP) programs to better ensure most effective delivery of services at time of need and to control costs and eliminate duplicate services. Availability of clinical data and meaningful use measures will assist in managing population health for those enrolled in OHCA programs.
Oklahoma Specific Business Processes – The MITA framework documents the basic business processes that most Medicaid Enterprises perform. In addition, it allows States to identify processes that are unique to that State. During the Provider Incentive Program Planning Phase MITA assessment, two unique business processes were identified as follows:
1.
Receive and Validate Provider Registration, Enrollment, and Attestation.
2.
Manage Regional Extension Center Referral and Coordination.
Oklahoma Health Care Authority
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4
NATURE AND SCOPE
This section will describe the activities that are covered in the IAPD funding request, and how resources will be acquired to satisfy the needs described in Section 3.3.2 above.
4.1
Planning
This section will describe the overall plan (references to SMHP would be appropriate) to implement the EHR Incentive payment program.
The OHCA will use the business processes described in the SMHP Section 4 to administer the Oklahoma EHR Provider Incentive Payment Program and distribute payments to eligible providers. The EHR Incentive Payment Program reporting to CMS will utilize existing business processes and established infrastructure to comply with all required reporting requirements. Any new reporting requirements by CMS will be incorporated into the existing reporting responsibilities.
4.1.1
System Modification Requirements
This section will include a list of the MMIS system modifications.
MMIS System modifications are described in the SMHP Section 5.1.2.3.3 Anticipated MMIS Modifications. The OHCA plans to complete these changes prior to January 2011 to support the Oklahoma EHR Incentive Payment Program. The OHCA will work with the MMIS support vendor to complete requirements definitions for each modification. These requirements will be based on understanding of the Final Rule, business processes developed to implement the program, and discussions with the MMIS support vendor.
A complete list of the HIT EHR Incentive Payments system changes, including the development time estimates from the MMIS support vendor, are shown by Change Order (CO) in Table 3 below.
Table 3 System Modification under Umbrella CO 10557
CO Number
Subsystem
CO Description
Remarks
Estimated Hours
10557
System Wide
EHR Incentive Payments
Project management
200
10221
Provider Data Maintenance
Provider Incentive Payment
provider online web screen
iCE portion
WF
COLD/RRI
533
250
300
60
10223
Financial
Incentive Payment for Providers
Finance batch
Finance iCE portion
630
250
10331
MAR
EHR Incentive payments - MAR
MAR Modifications
80
10333
Provider Data Maintenance
EHR Incent Paymts-NLR Interface
Interface with NLR
890
Total Estimated Hours
3,193
Oklahoma Health Care Authority
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4.1.2.2 Provider Outreach and Education Plans
A description for HIT Outreach and Education is included in Section 4.2 Communication Plan of
To achieve participation, the OHCA has completed or will complete the following activities:
 Obtain input via various methods/forums:
d a survey of eligible providers to determine
e
4.1.1.1
Develop and Implement System Changes
This section will describe the approach to system development and will include a description of the responsibilities for development.
The EHR Provider Incentive Program system enhancements will follow the same design, development, and implementation (DDI) approach and standards processes established for MMIS system change requests (SCR). The Provider Incentive Program SCRs have been prioritized by the OHCA for implementation to meet the January 2011 program start date. The current MMIS support vendor, Hewlett-Packard (HP), will be responsible for design, development, testing, and implementation of the EPE system changes as well as interfaces between EPE and the National Level Repository (NLR). The OHCA personnel will participate in user acceptance testing (UAT) activities and review all test results.
4.1.2
Operations
The OHCA plans to fully integrate the EHR Incentive Payment Program administration within day-to-day OHCA operations. An organizational chart is provided in the SMHP Section 4.1.10 Concept of Operations.
4.1.2.1
Communication
During the implementation phase, a procedure manual will be developed to communicate all facets of the Oklahoma EHR Provider Incentive Payment Program including eligibility, attestation, payment, recoupment, and provider appeals.
The Outreach, Education, and Information (OEI) work group is responsible for developing a planned approach for internal and external communications to ensure all stakeholders are adequately informed on progress made toward the implementation of the Oklahoma EHR Provider Incentive Payment Program. The OEI work group is responsible for all aspects of information sharing and works closely with all other work groups to ensure that appropriate information is shared, and that it is shared in a consistent manner.
The OEI work group has developed a Communications Plan for informing providers, the public, external agencies, and the media on progress made toward implementation of the Oklahoma EHR Provider Incentive Payment Program, and for sharing communications internally within the OHCA.
the SMHP. Additionally, detailed efforts planned within the next five months prior to program implementation include the efforts described below.
o
S
urveys – the OHCA has conducte
the current status of the provider’s EHR systems and at what level they anticipatachieving electronic health records in the near future. The survey also presented Oklahoma Health Care Authority
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an opportunity to make available information about the EHR Incentive Payment Program to providers.
o
Web input forms – Forms to collect various EHR-related bits of information will be available on the OHCA public web site under the Oklahoma EHR Provider Incentive Payment Program section.
o
Direct contact such as Training events – OHCA Provider Services and the contracted fiscal agent, HP, will train EPs and EHs. Fall 2010 training sessions already scheduled are listed below.
Sept 21, 2010 Sept 29, 30, 2010
Kiamichi Technical Center OSU - Tulsa Conference Auditorium
810 Waldron Road 700 N. Greenwood Avenue
Durant, OK Tulsa, OK
Oct. 14, 2010 Oct 26, 27, 2010
Great Plains Technology Center Moore Norman Technology Center
4500 SW Lee Boulevard South Penn Campus Conference Center
Lawton, OK 13301 S. Pennsylvania
Oklahoma City, OK
o
Telephone calls and follow-ups – Telephone contacts and follow-ups to surveys and other input will be completed by the OHCA Provider Services, contracted partners FOX and HP, and the EHR Planning, Development, and Implementation workgroup.
o
Public hearings – The OHCA is working with the Oklahoma State Department of Public Health to facilitate public hearings to gather input regarding the use of meaningful use outcomes and metrics in Oklahoma.
o
Meetings with professional health organizations, etc. – the OHCA will have ongoing meetings involving health organizations and other interested stakeholders, as there is new information or developments/benchmarks requiring further communication.

Conduct activities geared toward educating eligible professionals (EPs) and eligible hospitals(EHs). The OHCA will develop and maintain information regarding electronic health records to be used to educate providers. Educational activities will include:
o
Face-to-face training events
o
Multimedia presentations
o
Clear-cut messages via our secure provider web site
o
Informative e-mails and optional Internet web alerts
o
Pitching the importance of electronic health information to state health writers and media
o
Providing articles and news releases

News releases about electronic health records can be useful, especially in the rural newspapers. Also, articles written for specialized audiences, Oklahoma Health Care Authority
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4.1.2.5 Provider Payments
A detailed description for Provider Payment is included in the SMHP Section 4.6 Processing of
4.1.2.6 Provider Payment Monitoring
in Section 4.6.3 Provider Payment Monitoring.
n 4.7 Reporting Requirements.
such as eligible professionals and eligible hospitals, are an indirect means of reaching target audiences
o
Partnering with various agencies, related work groups, and professional health organizations
o
Partnering with other interested parties, which provides a means for additional contact with potentially eligible professionals and eligible hospitals, as well as members/consumers, and an opportunity to educate them about electronic health records
o
Directly contacting EPs and EHs via letters and phone calls. Contacting EPs and EHs is a great opportunity to educate them as well as get input.
o
Utilizing the web site and social media to share information. According to various sources, non-traditional media is an important source of health information, especially among the younger generations.
4.1.2.3
Provider Eligibility and Enrollment in EHR Incentive Payment Program
A detailed description for HIT Provider Eligibility and Enrollment is included in the SMHP Section 4.5 Provider Eligibility for Incentive Payments.
4.1.2.4
Provider Attestation
A detailed description for HIT Environment Registration and Attestation is included in the SMHP Section 3.2 Vision for HIT Environment.
Payments to Providers.
A detail
ed description is included in the SMHP
4.1.2.7 EHR Incentive Payment Reporting
A detail
ed description is included in the SMHP Sectio
Oklahoma Health Care Authority
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5
STATEMENT OF ALTERNATIVE CONSIDERATIONS
5.1
Description of Alternatives
This section describes any alternative analysis that was conducted, or state why none was necessary.
The OHCA considered one alternative to implementation of the EHR Provider Incentive Program as follows:
Alternative 1: Take no Action
1.
If the OHCA did not request the EHR Incentive Payment Administration FFP: The OHCA would not be in a position to implement MMIS modifications to receive electronic attestations nor validate provider registration in the NLR.
2.
The OHCA is not in a position to fund 100 percent of the positions required to support the Provider Incentive program from an administrative perspective.
3.
The OHCA could not produce required federal reporting or complete the required audit functions without federal funding.
No other alternatives were considered given the relative ability of the Oklahoma MMIS to allow providers to have secure access to the EPE system, process provider supplemental payments, as well as capture certain accounting and reporting requirements. The Oklahoma MMIS is the technical solution that most closely matches the business needs to support the EHR Provider Incentive Payment Program. Oklahoma Health Care Authority
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6
STATE RESOURCES
6.1
Medicaid Structure
In Oklahoma, the OHCA has the responsibility of administering the State’s Medicaid program. Created in 1993 by legislative authorization, the Designated Single State Medicaid Agency was transferred from the Department of Human Services to the OHCA, effective January 1, 1995. The agency’s mission “is to purchase state and federally funded health care in the most efficient and comprehensive manner possible, and to study and recommend strategies for containing costs and optimizing the accessibility and quality of health care.”
The agency must balance fiscal responsibility with two equally important goals:
1.
Assure that State-purchased health care meets acceptable standards of care.
2.
Ensure that citizens of Oklahoma who rely on State-purchased health care are served in a progressive and positive system.
6.2
OHCA Administration
The OHCA is governed by the Health Care Authority Board. Mr. Michael Fogarty is the current Chief Executive Officer of the Authority. The OHCA contains five operational areas and three administrative support groups. The eight major areas of the Authority are:
SoonerCare Operations:

Medical Professional Services

SoonerCare Program Operations & Benefits

Care Management

Medical Authorization Services

Insure Oklahoma

SoonerCare Provider Services

SoonerCare Member Services

SoonerCare Health Benefits Support

SoonerCare Quality Assurance/Quality Improvement

Opportunities for Living Life
o
Level of Care Evaluations
o
Long Term Care Quality Initiatives
o
Waiver Administration
Information Services:

Health Information Infrastructure Advisory Board

Contractor Systems Oklahoma Health Care Authority
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
Eligibility Automation and Data Integrity

Infrastructure Software and Support

Network Operations & Design

Database Administration

Application Development
Financial Services:

Provider Rates Analysis

Budget & Fiscal Planning

Financial Management

General Accounting

Purchasing

Federal Reporting

Financial Resources

Third Party Liability, Claims Resolution, and Adjustments
Policy, Planning, and Integrity:

Human Resources

Health Policy

Planning & Development

Program Integrity and Accountability

Provider Audits

Waiver Development & Reporting

Performance & Reporting
Legal Services:

Legal Operations

Contracts Development

Provider Contracting
Civil Rights Freedom of Information Act
Administrative Services
External Relations & Communications

Governmental Affairs Oklahoma Health Care Authority
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
Public Affairs

Federal/State Policy on Appropriations

Reporting & Statistics
6.2.1
OHCA Key Staff
Staff from the SoonerCare Program Operations Division and from the Policy, Planning, and Integrity Division will have primary responsibility for managing the project. Staff from the Information Systems Division will be the lead analysis and technical staff. Currently, certain staff members are charged with contract management tasks involved in overseeing development and operations.
Management-level representatives from other OHCA divisions and sections will participate in definition of requirements for the program, systems testing, acceptance testing, and implementation planning.
Key Roles anticipated for the OHCA staff include the following:

Becky Pasternick-Ikard, Deputy State Medicaid Director, project manager

Cindy Roberts, Deputy Chief Executive Officer, policy manager

John Calabro, Chief Information Officer, technical manager

Carrie Evans, Chief Financial Officer, financial manager
6.3
Administrative Costs
Additional State personnel resource needs are described in Section 3.2 Needs of this document. In addition, the OHCA plans provider outreach, training and travel related to the administration of the program. These costs are outlined in the table below
Table 4 Estimated Costs to Administer EHR Provider Incentive Payment Program
FFY 2011
FFY 2012
Cost Description
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Total
Enhanced Federal Funds 90% Participation
State Operational Staff
$152,798.63
$219,344.82
$219,344.82
$219,344.82
$219,344.82
$219,344.82
$219,344.82
$219,344.82
$1,688,212.34
Training & Outreach
11,250.00
38,250.00
11,250.00
11,250.00
11,250.00
11,250.00
11,250.00
11,250.00
117,000.00
Travel
4,500.00
4,500.00
4,500.00
4,500.00
4,500.00
4,500.00
4,500.00
4,500.00
36,000.00
Total Admin Enhanced FFP
$168,548.63
$262,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$1,841,212.34
OHCA Share Funding 10%
State Operational Staff
$16,977.63
$24,371.65
$24,371.65
$24,371.65
$24,371.65
$24,371.65
$24,371.65
$24,371.65
$187,579.15
Training & Outreach
1,250.00
4,250.00
1,250.00
1,250.00
1,250.00
1,250.00
1,250.00
1,250.00
13,000.00
Travel
500.00
500.00
500.00
500.00
500.00
500.00
500.00
500.00
4,000.00
Total OHCA Share Fdi
$18,727.63
$29,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$204,579.15
Total FFP and OHCA
$187,276.25
$291,216.46
$261,216.46
$261,216.46
$261,216.46
$261,216.46
$261,216.46
$261,216.46
$2,045,791.49
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7
SCOPE OF ACTIVITIES AND PROJECT METHODOLOGY
7.1
Project Approach
This section will describe the overall approach to the implementation of the Incentive Payment Program. Describe the manner in which the tasks are organized.
7.2
Tasks
7.2.1
Tasks Completed to Date
This section will list activities that have been completed in support of the EHR Incentive Payment Program.
The planning tasks completed to date in support of the Oklahoma EHR Provider Incentive Payment Program are listed below:

Contracted with a vendor, FOX, A Cognosante Company, to assist the OHCA in project management, SMHP development, and IAPD development

Obtained project appropriation from the Legislature

Completed the MITA SS-A As Is, To Be, Gap Analysis, and Roadmap

Identified and evaluated future business needs

Identified and evaluated current business needs not met by the current system

Identified and evaluated technological needs

Submitted SMHP to CMS and received approval on Sept. 3,2010
7.2.2
Tasks Underway at This Time

Submit IAPD for CMS approval

Develop Policy and Procedures required to support the Oklahoma EHR Provider Incentive Payment Program
7.2.3
Tasks to Be Undertaken
Implementation Advance Planning Document

Obtain IAPD approval from CMS

Submit revised SMHP to CMS for approval, and annually thereafter

Provide updated IAPD as necessary throughout the implementation and administration of the EHR Provider Incentive Payment Program
EHR Provider Incentive Payment Program Implementation

Obtain SMHP approval from CMS

Submit MMIS modifications to vendor Oklahoma Health Care Authority
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
Establish new policies for the Oklahoma EHR Provider Incentive Payment Program
7.2.4
Activity Schedule for the Project
This section will include a brief description of what is included in the schedule.
Table 5 Proposed Activity Schedule
Activity
Start Date
End Date
PAPD Activities
Project Planning
3/15/2010
Assess Current As Is Landscape
5/28/2010
Create HIT To Be Vision
5/30/2010
Develop Provider Incentive Program
8/13/2010
Update HIT Roadmap
6/30/2010
Develop SMHP
6/30/2010
IAPD
Develop IAPD
7/14/2010
7/31/2010
Submit IAPD to CMS
9/10/2010
CMS IAPD Review and Approval
10/10/2010
EHR Incentive Payment Program Implementation Preparation
MMIS Modifications
7/13/2010
1/7/2010
Test NLR Transactions with CMS
10/15/2010
11/1/2010
OHCA Policy and Procedure Revisions
7/13/2010
11/28/2010
Provider Manual Updates
7/13/2010
11/28/2010
EHR Incentive Payment Program Administration
Implement EHR Provider Incentive Payment Program
1/1/2011
Receive NLR Registration Transactions
1/1/2011
Receive Provider Attestations
1/1/2011
EHR Incentive Payment Program Payment Review & Authorization
1/1/2011
First Provider Incentive Payments
1/31/2011
Coordinate Provider Incentive Plan with stakeholders (e.g., Medicare, I/T/Us, and SHIECAP entities)
Ongoing
Coordinate Provider Incentive Plan with RECs
Ongoing
Identify Meaningful Use data collection requirements
6/30/2011
Identify Meaningful Use data collection solution
TBD
Develop IAPD Update to support data collection solution
TBD
Implement Meaningful Use data collection solution
TBD
A detailed Project Plan is included in Appendix B. Oklahoma Health Care Authority
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8
PROPOSED BUDGET
8.1
Overview
This section will include a description of the budget components.
Oklahoma’s proposed budget describes the costs associated with the administration of the EHR Incentive Payment Program, including:

State staff salaries and benefits to monitor and release payment requests, audit provider attestations, and support provider outreach, education, and inquiries

An estimate of the development costs associated with MMIS system modifications to support the administration of the Oklahoma EHR Provider Incentive Payment Program
The MMIS system modification costs are separated in the tables below from the Program Administration costs in alignment with the federal funding opportunities available from CMS under ARRA Section 4201.
All MMIS and EPE system modifications are listed in detail in the Oklahoma SMHP and are included in the MITA SS-A update and HIT Roadmap.
All cost estimates, methodologies, and allocations are in accordance with Section 11275 of the State Medicaid Manual, Chapter 11. The agreement includes a statement that the State will provide the requisite matching funds available for this project.
8.2
Budget by State and Federal Share
Tables 6 and 7 below identify the split between state and federal funds for each quarter.
Table 6 Estimated Quarterly Costs to Administer Program – Federal
FFY 2011
FFY 2012
Cost Description
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Total
Enhanced Federal Funds 90% Participation
HIT Administrative Costs
HIT In-house Planning
HIT Private Contractor Planning
HIT Implementation and Operation In-house Costs
$168,548.63
$262,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$1,841,212.34
HIT Implementation and Operation Costs Private Contractor
$211,950.00
$208,350.00
$204,750.00
$168,750.00
$276,750.00
$276,750.00
$276,750.00
$276,750.00
$1,900,800.00
Total Enhanced FFP
$380,498.63
$470,444.82
$439,844.82
$403,844.82
$511,844.82
$511,844.82
$511,844.82
$511,844.82
$3,742,012.34
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Table 7 Estimated Quarterly Costs to Administer Program – State
FFY 2011
FFY 2012
Cost Descriptions
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Total
OHCA Share Funding 10%
HIT Administrative Costs
HIT In-house Planning
HIT Private Contractor Planning
HIT Implementation and Operation In-house Costs
$18,727.63
$29,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$204,579.15
HIT Implementation and Operation Costs Private Contractor
$23,550.00
$23,150.00
$22,750.00
$18,750.00
$30,750.00
$30,750.00
$30,750.00
$30,750.00
$211,200.00
Total OHCA Share Funding
$42,277.63
$52,271.65
$48,871.65
$44,871.65
$56,871.65
$56,871.65
$56,871.65
$56,871.65
$415,779.15
*Total FFP and OHCA
$422,776.25
$522,716.46
$488,716.46
$448,716.46
$568,716.46
$568,716.46
$568,716.46
$568,716.46
$4,157,791.49
*Total Tables 6 and 7
Assumptions:
1.
The OHCA State Personnel will need to be available to administer the program beginning in January 2011.
2.
Tables 6 and 7 above include cost estimates for State and Contractor Personnel in 4th Quarter 2010, and estimated costs to implement and administer incentive payments during the first two FFYs of the program.
3.
As required by the Final Rule, costs shown by FFY and Quarter include: contractor cost to conduct requirements gathering for meaningful use Data Warehouse and bridge to integrate MMIS to OKHIE and develop resulting RFP and IAPDs; equipment and supplies; training and outreach; travel; personnel for administrative operations, and administrative expenses (e.g., costs for hardware and software DDI for MMIS and EPE systems as described in Section 4.1.1 of this IAPD).
4.
Report estimated costs in IAPD per CMS 64 reporting formats to allow alignment of estimated to actual costs. Oklahoma Health Care Authority
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October 15, 2010
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Combined Incentive Payments
Calendar Year
Table 8 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by Calendar Year
CY 2011
CY 2012
CY 2013
CY 2014
CY 2015
CY 2016
CY 2017
CY 2018
CY 2019
CY 2020
CY 2021
CY 2022
Total
EP
$30,812,500
$25,075,000
$23,800,000
$22,100,000
$22,950,000
$26,987,500
$11,475,000
$6,375,000
$3,825,000
$2,975,000
$2,125,000
$178,500,000
EH
$17,438,798
$43,015,703
$35,458,890
$15,694,919
$4,069,053
$581,293
$116,258,656
TOTAL
$48,251,298
$68,090,703
$59,258,890
$37,794,919
$27,019,053
$27,568,793
$11,475,000
$6,375,000
$3,825,000
$2,975,000
$2,125,000
$294,758,656
Combined Incentive Payments
State Fiscal Year
Table 9 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by State Fiscal Year
SFY 2011
SFY 2012
SFY 2013
SFY 2014
SFY 2015
SFY 2016
SFY 2017
SFY 2018
SFY 2019
SFY 2020
SFY 2021
SFY 2022
Total
EP
$15,406,250
$27,943,750
$24,437,500
$22,950,000
$22,525,000
$24,968,750
$19,231,250
$8,925,000
$5,100,000
$3,400,000
$2,550,000
$1,062,500
$178,500,000
EH
$8,719,399
$30,227,251
$39,237,296
$25,576,904
$9,881,986
$2,325,173
$290,647
$116,258,656
TOTAL
$24,125,649
$58,171,001
$63,674,796
$48,526,904
$32,406,986
$27,293,923
$19,521,897
$8,925,000
$5,100,000
$3,400,000
$2,550,000
$1,062,500
$294,758,656
* SFY 2011 is two quarters
Combined Incentive Payments
Federal Fiscal Year
Table 10 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by Federal Fiscal Year
FFY 2011
FFY 2012
FFY 2013
FFY 2014
FFY 2015
FFY 2016
FFY 2017
FFY 2018
FFY 2019
FFY 2020
FFY 2021
FFY 2022
Total
EP
$23,109,375
$26,509,375
$24,118,750
$22,525,000
$22,737,500
$25,978,125
$15,353,125
$7,650,000
$4,462,500
$3,187,500
$2,337,500
$531,250
$178,500,000
EH
$13,079,099
$36,621,477
$37,348,093
$20,635,911
$6,975,519
$1,453,233
$145,323
$116,258,656
TOTAL
$36,188,474
$63,130,852
$61,466,843
$43,160,911
$29,713,019
$27,431,358
$15,498,448
$7,650,000
$4,462,500
$3,187,500
$2,337,500
$531,250
$294,758,656
* FFY 2011 is three quarters Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 33
Assumptions:
1.
The program will begin in January 2011 and will therefore include only three quarters in FFY 2011, two quarters in SFY 2011.
2.
The program will sunset in December 2021.
3.
Anticipated EP EHR adoption rates are based on information gathered in an environmental scan conducted by the OHCA in May-June 2010 to understand a baseline rate of EHR usage among Medicaid providers. This environmental scan, while providing useful information regarding the interest in and use of EHR is not considered a research-based, nor statistically sound survey instrument.
4.
The SoonerCare program engages over 29,452 unduplicated providers; an estimated 6,349 are providers of the types eligible for the Incentive payments program. Forty-seven percent (47%) have reported usage of EHRs and 88 percent responding to the Environmental Scan planned participation in the program. There are 2,800 (approximately 50% of those planning participation) providers that are estimated to be eligible and receive Medicaid Incentive payments over the course of the program period.
5.
The OHCA has collaborated with the Oklahoma Hospital Association (OHA) to understand the rates of adoption and estimated incentive payment amounts for eligible hospitals in Oklahoma.
6.
The OHCA plans to disseminate payments to eligible hospitals over a three year period from the point that the hospital becomes eligible. Hospitals will receive 50 percent of their payment in the first year, 40 percent in the second year, and 10 percent in the third year. This payment structure is most favorable to encourage adoption by small, rural hospitals and ensures rapid incorporation of EHR systems in their facilities.
7.
The hospital growth factor applied is 1.33 percent annually.
8.
The estimates do not include potential eligible providers based outside of Oklahoma.
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 34
9
STATEMENTS OF ASSURANCES
The OHCA makes the following assurances in regards to this request for enhanced federal funding for the implementation and administration of the Oklahoma EHR Incentive Payment Program, including system modifications necessary to support the program.
The OHCA agrees with the following:

The system meets the system requirements and performance standards in Part 11 of the State Medicaid Manual (SMM).

The MMIS will support the data requirements of the Peer Review Organizations established under Part B of Title XI of the Social Security Act.

The OHCA has a royalty-free, non-exclusive, and irrevocable license to reproduce, publish, or otherwise use and authorize others to use for federal government purposes, software, modifications to software, and documentation that is designed, developed, installed or enhanced with 90 percent FFP.

The costs of the system will be determined in accordance with OMB Circular Number A-87 as referenced in 45 CFR 74.171.

The State of Oklahoma will provide the requisite matching State funds for the costs of this project.

The pertinent requirements of 45 CFR 95.612 on disallowance and of 45 CFR 95.621 on system security applies.

The contracts involving a fiscal agent (FA) will specify the contract conditions are firm and fixed during the life of the contract, and specify the pricing and conditions for changing the contract.

The contract must include a clause permitting cancellation of the contract within a specified time period if the FA is found out of compliance with the contract’s terms.
The request for 90 percent FFP is in accordance with the requirements at 42 CFR 433.112(5) and (6). The State of Oklahoma will include in the contract for services related to this IAPD the following requirements:

The OHCA will own any software that is designed, developed, installed, or improved with 90 percent FFP.

The U.S. Department of Health and Human Services (DHHS) has a royalty-free, non-exclusive, and irrevocable license to reproduce, publish, or otherwise use and authorize others to use, for Federal government purposes, software, modifications to software and documentation that is designed, developed, installed, or enhanced with 90 percent FFP.

The OHCA will assure that adequate security and privacy are maintained in the MMIS:
o
Security Requirements – The OHCA will ensure that information in the system will be safeguarded in accordance with Subpart F, Part 431 of 42CFR; and 45 CFR 164 Oklahoma Health Care Authority
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October 15, 2010
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o
Security and Contingency Plan

The OHCA may elect to perform annual security reviews of the contractor operations to ensure that the information contained in the MMIS will be properly safeguarded. Security standards used in the review will be based on industry standards and contain the components required under 42 CFR 95.621, Subpart (f) and 45 CFR 74 Subpart P.

The FA will be required to provide a contingency plan that includes measures to protect the MMIS data from errors or disasters, as well as procedures for error and disaster recovery, including an adequate back-up processing site. The OHCA will review the FA's security and contingency plan annually and request updates as necessary.
o
Interface Certification – The Work Order issued as a result of the approved IAPD will require the MMIS and all interfaces to be designed and conform to the requirements of Subpart F, Part 431 of 42CFR and the final security and 45 CFR 164. Once implemented, the OHCA will assure the MMIS and all interfaces are operated in compliance with these regulations. The Work Order will also require delivery of detailed plans for disaster recovery procedures and continuity of operations.
o
Disaster Recovery Procedure – The MMIS FA will be required to develop and maintain a Business Continuity Plan that addresses all aspects of disaster recovery for the MMIS. The business continuity plan will provide procedures for system restoration for emergencies and disasters, and for maintaining a state of readiness to meet the operational requirements of the MMIS. It will include a Disaster Recovery Plan.

The system must be compatible with the claims processing and information retrieval systems used in the administration of Medicare for prompt eligibility verification and for processing claims for persons eligible for both programs

The system must support the data requirements of quality improvement organizations established under Part B of title XI of the Act

The actual costs of the system will be determined in accordance with 45 CFR 74.171

The OHCA agrees that the information in the system will be safeguarded in accordance with subpart F, part 431 of this subchapter Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 36
10
CONCLUSION
This section will include the IAPD objectives and the funding request.
The OHCA’s objectives in preparing this IAPD are twofold. One objective in preparing this IAPD is to provide CMS:

A comprehensive description of the needs and objectives

The project scope

The project schedule

The requirements analysis and alternative considerations

The required resources

The proposed budget and cost distribution
The second objective is to request enhanced FFP for the resources needed to administer the Oklahoma EHR Provider Incentive Payment Program and 100 percent funding for Provider Incentive Payments.
The OHCA will be diligent in keeping CMS informed and involved throughout the EHR Provider Incentive Payment Program implementation and all related subsequent activities. The OHCA will seek CMS approval of all documents and activities as required. This document includes all information required by CMS and the appropriate federal regulations. The OHCA has taken great care to ensure this project is:

Well-planned and technically sound, and will be managed effectively

Consistent with CMS’ goals, such as promoting common claim forms and procedure coding, fostering Medicaid provider satisfaction, and meeting HIPAA and CLIA legislation

Cost-effective

Compliant with all federal and state procurement requirements
The State of Oklahoma is requesting CMS approval of this IAPD. The total funding anticipated from ARRA 4201 for this program includes $298,500,668. The breakdown is as follows:

$294.8 million at 100 percent FFP for provider incentive payments through 2021

Enhanced funding at 90 percent for program administration for FFYs 2011 and 2012 of $1,841,212 and federal share in HIT Administrative Costs

$1,900,800 in Contractor costs for FFYs 2011 and 2012

The OHCA will prepare IAPDUs to request program administration funding for the FFY 2013 through 2021 as the costs to administer meaningful use data collection are determined.
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 37
APPENDIX A: ACRONYMS
Acronym
Description
ARRA
American Recovery and Reinvestment Act of 2009
CMS
Centers for Medicare & Medicaid Services
CFR
Code of Federal Regulations
CBA
Cost Benefit Analysis
CHIPRA
Children’s Health Insurance Program Reauthorization Act of 2007
DDI
Design, Development, and Implementation
DW
Data Warehouse
DSS
Decision Support System
EDP
Electronic Data Program
EHR
Electronic Health Record
EHs
Eligible Hospitals
EMR
Electronic Medical Record
EPs
Eligible Professionals
EPE
Electronic Provider Enrollment
ER
Emergency Room
FA
Fiscal Agent
FFP
Federal Financial Participation
FFY
Federal Fiscal Year
FQHCs
Federally Qualified Health Centers
FOX
FOX, A Cognosante Company
GAO
Government Accountability Office
HIE
Health Information Exchange
HIIAB
Health Information Infrastructure Advisory Board
HIT
Health Information Technology
HMP
Health Management Program
HP
Hewlett-Packard
IAPD
Implementation Advance Planning Document
IHS
Indian Health Services
IAPD(s)
Implementation Advanced Planning Document(s)
I/T/U
Indian Health Services / Tribal facilities/Urban Indian Clinics
ITB
Invitation to Bid
IO
Insure Oklahoma
MARS
Management and Administration Reporting System
MEDai
Medical Artificial Intelligence
MITA
Medicaid Information Technology Architecture
MMIS
Medicaid Management Information System
NCPDP
National Council for Prescription Drug Programs Oklahoma Health Care Authority
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October 15, 2010
Page 38
Acronym Description
NLR
National Level Registry
NPI
National Provider Identifier
OEI
Outreach, Education, and Information
OFMQHIT
Oklahoma Foundation of Medical Quality Health Information Technology
OHA
Oklahoma Hospital Association
OHCA
Oklahoma Health Care Authority
OK
State of Oklahoma
OKHIE
Oklahoma Health Information Exchange
OLL
Opportunities for Living Life
ONC
Office of the National Coordinator for Health Information Technology
OSF
Oklahoma Office of State Finance
OSMA
Oklahoma State Medical Association
OSUCRH
Oklahoma State University Center for Rural Health
P-APD
Planning Advance Planning Document
PI
Program Integrity
REC
Regional Extension Center
RFP
Request for Proposal
RHCs
Rural Health Centers
SCR
System Change Request
SHIECAP
State Health Information Exchange Cooperative Agreement Program
SMHP
State Medicaid Health Information Technology Plan
SMM
State Medicaid Manual
SS-A
State Self-Assessment
SURS
Surveillance Utilization Review System
TIN
Taxpayer Identification Number
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
APPENDIX B: PROJECT PLAN
Page 39
I Oklahoma Health Care Authority
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APPENDIX C: MITA SS-A UPDATE
The table below contains a list of all identified MITA business processes impacted by the Oklahoma EHR Provider Incentive Payment Program. It includes those processes affected by meaningful use requirements as well as those with an opportunity for higher MITA Maturity Capabilities Level. These improvements in the MITA Maturity Level can be achieved if more automated processes are implemented and business process changes are.
MITA BP Number
MITA Business Process Name
Issues and Opportunities
PIP and SMHP
Opportunities for Improvements
Current MITA Maturity Level
New MITA Maturity Level based on IAPD Request
Member Management
ME 01
Determine Eligibility
PIP will need access to determine eligibility information as input to measuring target patient % met for provider Medicaid population.
HIT/HIE provides opportunity for centralized patient index/Master patient index (central patient identity resolution)locator and registry.
Significant opportunity to improve semantic interoperability between state’s eligibility system and MMIS if standard Metadata used.
1
1
ME 02
Enroll Member
HIT/HIE provides opportunity for centralized patient index/Master patient index (central patient identity resolution)locator and registry.
Significant opportunity to improve semantic interoperability between state’s eligibility system and MMIS if standard Metadata used.
1
1
ME 03
Disenroll Member
HIT/HIE provides opportunity for centralized patient index/Master patient index (central patient identity resolution)locator and registry.
Significant opportunity to improve semantic interoperability between state’s eligibility system and MMIS if standard Metadata used.
1
1
ME 04
Inquire Member Eligibility
Member Eligibility supports the health information exchange goals to provide eligibility inquiry capabilities.
Extend the member eligibility inquiry function to HIE participants to validate eligibility real time.
2
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MITA BP Number MITA Business
Process Name
Issues and Opportunities
PIP and SMHP
Opportunities for Improvements Current MITA
Maturity Level
New MITA
Maturity Level
based on IAPD
Request
ME07
Manage Applicant & Member Information
HIT/HIE provides opportunity for centralized patient index/Master patient index (central patient identity resolution) locator and registry.
Significant opportunity to improve semantic interoperability between state’s eligibility system and MMIS if standard Metadata used.
1
1
ME 08
Perform Population and Member Outreach
HIT/HIE provides opportunity for centralized patient index/Master patient index (central patient identity resolution)locator and registry.
Significant opportunity to improve semantic interoperability between state’s eligibility system and MMIS if standard Metadata used.
1
1
Provider Management
PM 01
Enroll Provider
Electronic Provider Enrollment (EPE) is leveraged to capture provider attestation and program enrollment. The provider is able to enroll online, signify attestation and request incentive payment.
Providers could electronically submit attestation documentation.
Notices regarding annual payments, information regarding PIP, MU etc.
1
2
PM 02
Disenroll Provider
Capability to disenroll online is not automated and is entirely a manual process and manual errors may occur. Disenrollment due to sanctions of prescribers is not automated; electronic file is shared throughout the agency. Notification of provider disenrollment, termination or death is manually verified through the licensing board or physician’s office communication is not always timely.
Significant opportunity to improve timeliness of disenrollment and eliminate data entry errors through automated exchange of information.
2
2
PM 04
Manage Provider Communication
EPE allows providers to enroll and electronically submit required documentation. PIP will increase the number of provider communication opportunities.
Consider implementation of contact management solution tied to MMIS.
1
1 Oklahoma Health Care Authority
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MITA BP Number MITA Business
Process Name
Issues and Opportunities
PIP and SMHP
Opportunities for Improvements Current MITA
Maturity Level
New MITA
Maturity Level
based on IAPD
Request
PM 05
Manage Provider Grievance and Appeal
Providers will have the ability to appeal an eligibility decision based on the patient volume, meaningful use of EHR data, or Adoption, Implementation, Upgrade documentation. In addition, providers will be able to appeal the incentive payment amount.
Provider appeals information could be integrated.
1
1
PM 06
Manage Provider Information
Provides access to records as required by Provider Management Area business processes workflow.
Opportunity for further enhancement to automate upload of provider information from NLR data base.
2
2
PM 07
Perform Provider Outreach
Currently no formal process for assessing impact of provider outreach; no centralized repository for obtaining and coordinating outreach activities and provider visits.
Opportunity for further enhancement to centralize collection and storage of provider communications.
2
2
State Specific
Receive and Validate Provider Registration, Enrollment and Attestation
PIP requires management of information regarding a provider’s annual request and eligibility and registration in PIP. Providers will at a minimum attest that they have a certified EHR, 30% Medicaid patient volume, able to meet meaningful use and has complied with the rules regarding participation.
Further enhancement to allow providers to submit electronic copies of documentation supporting attestation.
NEW
2
State Specific
Manage Regional Extension Center Referral and Coordination
Give providers the REC contact information or forward provider requests to the REC.
Explore opportunities for specific ongoing activities that could be automated, including central storage of referrals and communications with REC.
NEW
1 Oklahoma Health Care Authority
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October 15, 2010
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Business Relationship Management
BR 01
Establish Business Relationship
Establish business relationships process is manual.
1
1
Contractor Management
CO 03
Manage Administrative or Health Services Contracts
The OHCA has modified provider contracts to include a requirement that providers leverage e-prescription opportunities and reporting of lab results.
1
1
CO 06
Manage Contractor Communication
Communication is performed manually. MMIS specific communications for Change Control & Management are not comprehensive and notification sporadic.
Improved communication tracking could lead to better program efficiencies and consistent messaging to stakeholders.
1
2
CO 07
Perform Contractor Outreach
Administration of the PIP requires extensive and ongoing outreach to providers. The SMHP describes the efforts the OHCA intends to apply to engage providers in this opportunity.
Explore opportunities for specific ongoing activities that could be automated.
1
1
Operations Management
OM 10
Prepare Provider EFT Check
Currently 80% providers receive EFTs. Automated check process unless paper check required. RAs and paper checks manually matched.
Opportunity to issue provider incentive payment via EFT.
2
2
OM 18
Inquire Payment Status
PIP will require that providers are able to inquire as to the status of their PIP payment request. The OHCA intends to leverage existing functionality.
2
2
OM 19
Manage Payment Information
PIP will require that incentive payments are managed separately to support Federal reporting requirements.
Explore opportunities for specific ongoing activities that could be automated.
2
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OM 24
Manage Recoupment
PIP requires that provider payments made in error or through fraud be recouped by the SMA. The OHCA intends to leverage existing business processes and functionality when errors or fraud are detected.
Explore opportunities for specific ongoing activities that could be automated.
2
2
Program Management
PG 01
Designate Approved Services/Drug Formulary
Automatic interpretation of NDC file is not working, requiring manual review. System changes required for some codes and not always completed timely. Source for HCPCS/CPT code information is not established and may not be timely.
2
2
PG 05
Develop and Maintain Program Policy
PIP requires that policies are in place that support the Final Rule (INSERT RULE NO) and clarify local decisions regarding the calculation of patient percentage, coordination with border states.
Looking at getting public comment each time a change is going to be made. The proposed changes will be posted with a blog to allow for comments prior to making the change permanent. These changes will be accepted electronically.
Will develop a process to notify stakeholders of all policy related changes. This would include
waivers, state plan, policy, etc.
2
2
PG 12
Generate Financial and Program Analysis/Reports
PIP requires Financial and program analysis and reporting. Reports must segregate the Incentive Payments and Administrative Costs.
2
2
PG 14
Manage Program Information
Program analysis and reporting needs of PIP are managed in DSS.
2
2
PG 15
Perform Accounting Functions
The OHCA utilizes multiple siloed accounting systems. No integration between MARS, DSS, and financial data. Internal account coding and quarterly expenditure coding not aligned.
1
2 Oklahoma Health Care Authority
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PG 16
Develop and Manage Performance Measures and Reporting
PIP requires providers to electronically submit the data supporting Meaningful Use Measures. The SMHP describes the Year 1 approach, accepting provider attestations that Meaningful use data collection is occurring.
Meaningful Use (MU) data, measures and objectives stored in a data warehouse will allow the OHCA to automatically determine provider PIP eligibility related to MU. In addition, the SMA will have access to a data source that will provide a basis for measuring programmatic outcomes.
1
1
PG 17
Monitor Performance and Business Activity
No integrated systems to collect and report on performance activities. Lack of access to data from other state agencies and other states. Inability to drill down to detail performance data.
The OHCA plans to implement meaningful use data warehouse under separate chapter to this IAPD.
1
1
Program Integrity Management
PI 01
Identify Candidate Case
The PIP requires audit of the Provider’s EHR data as it supports the meaningful use of this data. It will be necessary to use existing tools to validate the measures and data submitted by the providers to qualify for incentive payments.
In the future additional tools may be used to expand criteria used to complete audits.
It is hoped that further demonstrations from vendors will be presented to help with:
·
Data analysis
·
Algorithms
·
Queries, etc.
The OHCA hopes to gain additional experience and ideas from other state agencies in this area.
1
1
PI 02
Manage Case
Program Integrity unit will need to identify the detailed steps required in the Provider Meaningful use data audit that will be conducted.
1
1
Care Management
CM 01
Establish Case
PIP could provide an opportunity to integrate member cases and EHR to most effectively deliver services and control costs.
Additional integration between the MMIS and the Eligibility systems can enhance the effectiveness of member support.
1
1
CM 02
Manage Case
Begin sending risk scores and diagnosis to the HMP contractor with predictive modeling tool
1
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CM 03
Manage Medicaid Population Health
The PIP through the Meaningful Use requirements will improve the availability of information available to evaluate and manage population health with EHR in addition to claims and PQRI data.
OCHA wants to develop an efficient way to integrate data across the state and have this information put in a centralized location for all to view.
In the future, the OHCA would like to have resources that specialize in analyzing data and implementing strategies as an outcome of analyzing data.
1
1
CM 04
Manage Registry
PIP Meaningful use optional criteria in Year 1 includes the integration of public heath data such as immunization and electronic health surveillance information.
Predictive Modeling System could be used as a Registry.
The Atlantes System has a future version with capabilities for Predictive Modeling.
HMP Providers are entering clinical data in their Registry and that data is not available to the OHCA.
The OHCA would like to integrate this information into the MMIS. (Interfacing HMP data with the
MMIS.)
HIE will need to leverage state-wide assets such as immunization, birth & death registries to support the health reform initiatives.
1
1

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IMPLEMENTATION
ADVANCED PLANNING DOCUMENT
October 13, 2010
Version 1.0
Submitted by the
Oklahoma Health Care Authority
on behalf of the State of Oklahoma
With technical assistance provided by:
6263 North Scottsdale Road
Scottsdale, AZ 85250
(480) 423-8184
www.cognosante.com
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 13,2010
Page i
TABLE OF CONTENTS
1 EXECUTIVE SUMMARY.....................................................................................................1
1.1 Purpose............................................................................................................................1
2 THE IMPLEMENTATION ADVANCE PLANNING DOCUMENT (IAPD)............................2
2.1 Preparation for the IAPD...................................................................................................2
2.1.1 As Is HIT Landscape Assessments................................................................................2
2.1.2 To Be Vision...................................................................................................................3
2.1.3 Actions to Implement Oklahoma EHR Provider Incentive Payment Program................3
2.1.4 Audit Strategy.................................................................................................................4
2.1.5 HIT Roadmap.................................................................................................................4
3 STATEMENT OF NEEDS AND OBJECTIVES...................................................................5
3.1 Roadmap Projects.............................................................................................................5
3.1.1 Federally Mandated Projects..........................................................................................5
3.1.2 OHCA Priorities..............................................................................................................5
3.1.3 Enhancements...............................................................................................................5
3.2 Needs...............................................................................................................................7
3.3 MITA SS-A......................................................................................................................10
3.3.1 Executive Goals and Objectives...................................................................................11
3.3.2 Needs Relating to State Self-Assessment...................................................................15
4 NATURE AND SCOPE......................................................................................................18
4.1 Planning.........................................................................................................................18
4.1.1 System Modification Requirements..............................................................................18
4.1.1.1 Develop and Implement System Changes................................................................19
4.1.2 Operations....................................................................................................................19
4.1.2.1 Communication.........................................................................................................19
4.1.2.2 Provider Outreach and Education Plans...................................................................19
4.1.2.3 Provider Eligibility and Enrollment in EHR Incentive Payment Program...................21
4.1.2.4 Provider Attestation...................................................................................................21
4.1.2.5 Provider Payments....................................................................................................21
4.1.2.6 Provider Payment Monitoring....................................................................................21
4.1.2.7 EHR Incentive Payment Reporting............................................................................21
5 STATEMENT OF ALTERNATIVE CONSIDERATIONS...................................................22
5.1 Description of Alternatives..............................................................................................22
6 STATE RESOURCES........................................................................................................23
6.1 Medicaid Structure..........................................................................................................23
6.2 OHCA Administration......................................................................................................23
6.2.1 OHCA Key Staff...........................................................................................................25
6.3 Administrative Costs.......................................................................................................26
7 SCOPE OF ACTIVITIES AND PROJECT METHODOLOGY............................................27
7.1 Project Approach.............................................................................................................27
7.2 Tasks..............................................................................................................................27
7.2.1 Tasks Completed to Date.............................................................................................27 Oklahoma Health Care Authority
Implementation Advance Planning Document
October 13,2010
Page ii
7.2.2 Tasks Underway at This Time......................................................................................27
7.2.3 Tasks to Be Undertaken...............................................................................................27
7.2.4 Activity Schedule for the Project...................................................................................28
8 PROPOSED BUDGET.......................................................................................................29
8.1 Overview........................................................................................................................29
8.2 Budget by State and Federal Share................................................................................30
9 STATEMENTS OF ASSURANCES...................................................................................34
10 CONCLUSION...................................................................................................................36
APPENDIX A: ACRONYMS.......................................................................................................37
APPENDIX B: PROJECT PLAN................................................................................................39
APPENDIX C: MITA SS-A UPDATE..........................................................................................40
LIST OF FIGURES
Figure 1 Percentage of Providers Reporting EHR/EMR by Group...............................................2
Figure 2 To Be Roadmap..............................................................................................................6
LIST OF TABLES
Table 1 Additional Resources to Support EHR Incentive Payment Program...............................7
Table 2 Executive Guiding Principles and Objectives.................................................................11
Table 3 System Modification under Umbrella CO 10557............................................................18
Table 4 Estimated Costs to Administer EHR Provider Incentive Payment Program...................26
Table 5 Proposed Activity Schedule...........................................................................................28
Table 6 Estimated Quarterly Costs to Administer Program – Federal........................................30
Table 7 Estimated Quarterly Costs to Administer Program – State............................................31
Table 8 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by Calendar Year............................................................................................................................32
Table 9 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by State Fiscal Year.................................................................................................................................32
Table 10 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by Federal Fiscal Year.....................................................................................................................32
Oklahoma Health Care Authority
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1
EXECUTIVE SUMMARY
1.1
Purpose
The section provides a high-level executive summary for the request by the State of Oklahoma for enhanced federal financial participation (FFP) from the CMS in accordance with Federal regulations. This request supports the administration of the EHR Incentive Payment Program and the administrative efforts required to support the SMHP Implementation activities.
The Oklahoma Health Care Authority (OHCA) is the single state agency that administers the Oklahoma Medicaid program. The State of Oklahoma has elected to participate in the Electronic Health Record Provider Incentive Payment Program funded through CMS. This Implementation Advance Planning Document (IAPD) is a request by the OHCA on behalf of the State of Oklahoma for enhanced federal financial participation (FFP) from the Centers for Medicare & Medicaid Services (CMS) in accordance with Federal regulations1. The State Medicaid Health Information Technology Plan (SMHP) was submitted for consideration by CMS on August 3, 2010, and approval received on September 3, 2010.
This request supports the first phase of the state’s participation in the development and expansion of the use of Electronic Health Records (EHR) and collaboration among state entities in a Health Information Exchange (HIE) network. In the first phase, the OHCA will implement the system changes necessary to support the Oklahoma EHR Provider Incentive Payment Program as well as the administrative supports necessary for implementation and operation of this program.
Effective September 3, 2010, the OHCA will close the Planning Advance Planning Document (P-APD) submitted to CMS in December 2009 and open the IAPD, adding chapters to this IAPD to request funding for future projects as details of the projects become known.
The OHCA anticipates that the system changes will be completed, tested, and implemented by January 1, 2011 in preparation for provider registration beginning in January 2011 and subsequent eligible provider payments.
The OHCA requests on behalf of the State of Oklahoma $3,742,012.34 to support the Oklahoma EHR Provider Incentive Payment Program implementation costs, including State staff, contractor costs, and expenses associated with provider training and outreach. The State anticipates provider incentive payments will be made to approximately 1,450 eligible professionals (EPs) and 130 hospitals (which includes six Indian Health Services (IHS) hospital facilities) in calendar year 2011, totaling $48,251,298. This includes an estimated $17,438,798 to eligible hospitals and $30,812,500 to EPs. Related MMIS modifications are reimbursable under the Section 4201 of the American Recovery and Reinvestment Act (ARRA).
As the program is further defined by CMS, and tools are refined by the Office of the National Coordinator of Health Information Technology (ONC), the State’s SMHP will be updated with changes in policy and process, and this IAPD will be updated to include costs as necessary. The Oklahoma Health Information Exchange (OKHIE) Strategic and Operations Plans are not approved and the SMHP must be aligned following their approval. At a minimum, the SMHP will be updated annually.
1 Part 11 of the State Medicaid Manual (SMM) & 42 CFR subpart C - 433.112(a) Oklahoma Health Care Authority
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2
THE IMPLEMENTATION ADVANCE PLANNING DOCUMENT (IAPD)
2.1
Preparation for the IAPD
This section will describe the activities supporting the development of the IAPD; including the development and submission of the SMHP, as well as the visioning, selection and planning for the set of initiatives described in this request.
This IAPD has been developed following the submission of the SMHP on August 3, 2010. The Health Information Technology (HIT) P-APD outlined the tasks and activities necessary to complete the SMHP and IAPD to support the Oklahoma EHR Provider Incentive Payment Program. Excerpts from the SMHP are provided here to inform on the results of the SMHP planning activities. Readers should refer to the SMHP document for detailed information.
The OHCA conducted assessments, analysis, and planning activities in the following five areas as required by CMS during the preparation of the SMHP. High-level results are as follows.
2.1.1
As Is HIT Landscape Assessments
The OHCA has conducted the As Is HIT Landscape Assessments for professionals, hospitals, Federally Qualified Health Centers (FQHCs)/Rural Health Centers (RHCs), and Indian Health Services/Tribal Facilities/Urban Indian Clinics (I/T/U). Results were shared with OKHIE, Oklahoma Foundation of Medical Quality Health Information Technology (OFMQHIT), the Oklahoma Hospital Association (OHA), Oklahoma State Medical Association (OSMA), Oklahoma Office of State Finance (OSF), and Oklahoma State University Center for Rural Health (OSUCRH). OKHIE is currently conducting an environmental scan for networks and these results will be shared with the OHCA when available. The methodology, survey questions, participants, timeline, and results are available in the SMHP. The results of overall EHR adoption across the different provider groups targeted in the scans are shown in Figure 1 Percentage of Providers Reporting EHR/EMR by Group. “Presumed eligible” providers were those that self-reported meeting the patient volume requirements established in the proposed rule and were enrolled in an eligible provider type. Page 2
Figure 1 Percentage of Providers Reporting EHR/EMR by Group Oklahoma Health Care Authority
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There were a number of initiatives identified that impact SoonerCare members, including several quality improvement initiatives; use of telemedicine to improve access to care for members in rural or underserved areas; electronic eligibility and claims transactions; ePrescribe capabilities, clinical lab ordering and results delivery; and public health reporting.
Additionally, the OHCA collaborated with stakeholders and conducted a comprehensive statewide assessment of HIT assets available to determine how these may be leveraged in the future to improve care coordination of SoonerCare Members. Stakeholders collaborating in these efforts include: Health Information Infrastructure Advisory Board (HIIAB), OKHIE, Broadband grantee, Beacon Communities grantee, OFMQHIT, OSMA, OHA, and other stakeholders.
Broadband penetration across Oklahoma is a barrier to health information exchange with providers in rural areas. There are numerous federal funding agencies for broadband efforts and Oklahoma stakeholders have applied for and received grants under several funding sources.
2.1.2
To Be Vision
The OHCA’s vision for the future anticipates improvements in health outcomes, clinical quality, and efficiency in multiple physical and behavioral healthcare management environments with increased usage and interoperability of EHR systems. Best practices and trends in direct care and care coordination efforts can be identified by expanding reporting capabilities and evaluating outcomes data. Potential and actual cost impact can be calculated to guide further program development. Utilization review endeavors can be enhanced from both pre-payment and post payment perspectives. Through developments in data exchange through HIEs, provider access to data will further enhance care coordination opportunities, eliminate duplication of service, and foster identification of appropriate levels of care. Similarly, the OHCA, on behalf of SoonerCare members, will be able to more effectively identify serious quality of care issues, gaps in care, member compliance issues, and member behavior trends in areas such as Emergency Room (ER) utilization.
The OKHIE Strategic and Operational Plans are not approved and a comprehensive vision for statewide HIT/HIE is not available at this time. Thus, the OHCA will update its SMHP after further collaboration with OKHIE and development of these statewide plans. The OHCA plans to align its vision with the statewide vision once approved.
2.1.3
Actions to Implement Oklahoma EHR Provider Incentive Payment Program
The OHCA business areas reviewed the regulatory requirements for submission of the SMHP published in the Final Rule at §495.332 and in CMS guidance for developing the SMHP published on April 29, 2010. Work groups were formed in alignment with the OHCA’s current concept of operations. These work groups then reviewed each business process that has been affected or will be implemented to develop a concept of operations for the Oklahoma EHR Incentive Payment Program. Where feasible, the approach adopted was to integrate the Oklahoma EHR Incentive Payment Program business process into the OHCA’s corresponding standard Medicaid Information Technology Architecture (MITA) business processes. Oklahoma Health Care Authority
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2.1.4
Audit Strategy
The OHCA Program Integrity (PI) adheres to Government Auditing Standards (The Yellow Book) developed and maintained by the Government Accountability Office (GAO). The OHCA PI staff in the Policy, Planning, and Integrity Division have been involved in the review of the regulatory requirements and the Final Rule, and participated in numerous CMS guidance opportunities (e.g., webinars, conference calls, and meetings). Wherever possible, the OHCA PI staff will work to incorporate the post-payment audits needed to support the Oklahoma Provider Incentive Payment Program into ongoing, regular provider audits. Further, the OHCA operations will engage in prepayment evaluation of provider attestation material and related documents to ensure the provider’s eligibility for the program. By coordinating pre- and post-payment activities, the OHCA will minimize the risk of overpayment or fraudulent payments under this program. The SMHP in Section 5.1.2.1 describes in detail the processes supporting the necessary internal and external controls, and the OHCA audit strategy.
2.1.5
HIT Roadmap
The SMHP includes a description of the modifications to the MITA Roadmap to include HIT and Provider Incentive Payment Program activities. The April 1, 2010 submission of the HIT Roadmap with the MITA State Self-Assessment (SS-A) anticipated HIT-related activities. These activities were further developed in the SMHP to show the HIT Roadmap for near-term projects.
The OHCA is deferring some of its longer-term planning and benchmark development for HIT/HIE awaiting the OKHIE to complete its Strategic and Operational Plans. Separate IAPDs will be submitted to construct a bridge from the MMIS to the OKHIE and to procure a Meaningful Use Data Warehouse. The OHCA dialog with the HIIAB, Broadband grantee, and Beacon Communities grantee is underway. When details of these projects are fully understood, including a timeline for projects, the SMHP will be updated and separate IAPD requests for funding will be submitted. Oklahoma Health Care Authority
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3
STATEMENT OF NEEDS AND OBJECTIVES
This section will describe the projects and administrative activities that are covered in the IAPD.
Medicaid Management Information System (MMIS) enhancements are required to support administration of the Oklahoma EHR Provider Incentive Payment Program. The OHCA plans to implement the Incentive Payment Program in January 2011.
3.1
Roadmap Projects
Projects listed on the HIT Roadmap are grouped into three different categories for the purpose of identifying their origin.
3.1.1
Federally Mandated Projects
Federally mandated projects are not optional and must be completed as required by legislation, a rule, or regulation. These projects have pre-defined implementation dates dictated by the applicable regulatory body.
3.1.2
OHCA Priorities
Projects identified by Executive Staff as an OHCA priority must be completed to better assist agency staff in performing their daily business activities and ensure that programs and services respond to the needs of members by providing necessary benefits and improved health care access.
3.1.3
Enhancements
Enhancements originated from an initial list of over 500 requirements identified by the business users as functionality that, if implemented, would improve current business processes. The requirements contained a myriad of improvement techniques, including increased automation, elimination of duplicative processes, enhanced data mining and metrics, improved communication and correspondence tracking, among many others. The initial list of 500 plus requirements went through several rounds of consolidation. After final consolidation, requirements were grouped into 39 different categories. The categories were then prioritized and from the initial list of 39, 10 were identified for inclusion within the Roadmap.
The complete list of Roadmap projects including enhancements can be viewed in Figure 2 To Be Roadmap below. This HIT Roadmap will be updated to further define the ARRA/HIE/EHR projects and timeline in future chapters to this IAPD as the specifics of the projects are known.
Oklahoma Health Care Authority
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October 15, 2010
Figure 2 To Be Roadmap
X12 5010 and NCPDP TransactionsICD-10 PlanningICD-10 ImplementationARRA/HIE/EHRHealthcare ReformSelf-Directed Services (MFP)Online EnrollmentInsure OK & CHIPRAMMIS Documentation UpdatesRegression Testing GeneratorProgram IntegrityCTI and Call TrackingDocument Mngmnt/ImagingLetter Generation/CorrespndceMedical Policy Review & Eval.Claims - Rules EngineClaims - Resolutions WorkflowSecure Provider PortalSecure Member PortalFinance2017Phase IIIPhase IIab2016Phase IOHCA Priorities2014201220112010Project PhasesEnhancements2013Mandates2009Calendar YearProjects2015Issue RFPAwardHardware TRANSITIONCurrent FA Operations End TakeoverDDI Continuing Operations + DDI1 yr optionContinuing Operations Page 6
Oklahoma Health Care Authority
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October 15, 2010
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All MMIS enhancements, excluding Oklahoma Provider Incentive Payment Program system changes are included within the current RFP, and were funded in a separate IAPD request submitted to CMS on April 1, 2010.
3.2
Needs
This section will describe the needs the OHCA has identified that must be fulfilled in order to support the EHR Incentive Payment program administration as described in the SMHP document.
The OHCA has identified the following needs that must be fulfilled in order to support the EHR Incentive Payment Program administration: These enhancements are described in the Oklahoma SMHP submitted to CMS on August 3, 2010. Generally, the enhancements include:
1.
Modifications to the Oklahoma Provider Portal – Electronic Provider Enrollment (EPE) to allow providers to attest to their eligibility for the EHR Incentive payment.
2.
An interface to the National Level Registry (NLR) to exchange information regarding the provider registration information, including the National Provider Identifier (NPI) and Tax payer Identification Number (TIN) numbers used to register with CMS and the amount and timing of the incentive payment. The database will inform the OHCA in the event the provider has registered for incentive programs in any other states and/or the Medicare Program.
3.
Modifications to the MMIS Financial Module to uniquely account for the incentive payments by adding new accounting codes, updating reports, and developing a panel to support the calculation of provider incentive payment amounts.
4.
Modifications to the Management and Administrative Reporting System (MARS) to accommodate required federal and internal reporting of the incentive payments as well as program administration costs.
The OHCA has thoroughly reviewed and planned for adequate staff to meet Oklahoma EHR Provider Incentive Payment Program objectives. Oklahoma plans to administer the program by leveraging existing OHCA support units (see Section 4.1.10), as well as supplement existing State staff with new positions as identified in Table 1 Additional Resources to Support EHR Incentive Payment Program, which includes the position description and responsibilities for new staff supporting the program.
Table 1 Additional Resources to Support EHR Incentive Payment Program
Positions Needed
Position
Description
Responsibilities
Annual Salary
1
Data Processing/
Planning Specialist
Conducts system and data analysis, develops requirements, assists in validation of system design and test results.
Assist senior analysts with healthcare interoperability projects such as data sharing with the statewide Health Information Exchange , system modifications necessary to support EHR incentive payments, data warehouse for meaningful use criteria and reporting, telemedicine and other interoperability efforts of the
$47,739 Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
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Positions
Needed
Position Description Responsibilities Annual
Salary
agency.
2
Financial Information Analyst
Plans, directs, and coordinates EHR incentive payment program fiscal operations and financial accounting functions. Develops accounting systems and procedures for recording revenues and expenditures. In addition to the current Financial Information analyst position duties
The OHCA will begin making EHR incentive payments to EPs and EPs in January 2011. These payments will need to be managed separately from all other payments to providers. Close coordination with CMS is required to track the payments for accuracy and adherence to policy. Eligible providers may select to begin the program in different years and/or not participate in consecutive years creating a complex payment structure which will require new monitoring methods by Finance to ensure payments are made correctly. A different payment structure is required for payments to hospitals.
$60,846
1
Provider Education Specialist
Provide direct and indirect support for the health care community. Aid eligible providers and hospitals with EHR incentive payment questions. Provide outreach and education to the healthcare community.
EHR incentive payment program requirements are complex. The OHCA will need additional staff to answer questions/calls regarding EHR incentive payments. Additional SoonerCare representation will be required at provider association meetings, individual facilities and the regional extension centers. Additional SoonerCare provider training sessions will be needed to support the program.
$46,850
2
EDP Auditors
Conduct onsite audits of provider and facility EHR systems to ensure compliance with Federally defined meaningful use criteria. Provide technical support to providers and other OHCA auditors on policy issues, such as
Electronic Data Program auditors review systems for compliance. The auditing requirements for the EHR incentive payment program are complex and require the ability to understand how “the EHR system” works internally. An auditor is needed to review “the EHR system” to augment the
$71,119 Oklahoma Health Care Authority
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Positions
Needed
Position Description Responsibilities Annual
Salary
electronic signature verification.
OHCA auditing staff when reviewing meaningful use compliance.
2
Legal Policy Analyst
Reviews documentation submitted to support provider attestation prior to payment approval.
The Legal Policy Analysts will assist in drafting new Oklahoma EHR Provider Incentive Payment program sections for the Provider Manual, review and draft responses to provider payment appeals, and provide interpretation of program rules upon request from the OHCA, Fiscal Agent and/or providers.
$71,119
1
Network
Administrator
Supports provider request for assistance by documenting software issues, and providing hands-on troubleshooting with provider to resolve data format issues.
Receive telephone calls from providers and attempt to resolve computer/software problems. Complete trouble tickets and compile weekly management reports. Provide technical support to providers.
$46,850
1
Network Administrator
Supports network computers, servers, and printers to ensure connectivity to providers and other external stakeholders.
Monitor network functioning for optimal levels; troubleshoot issues with connectivity; monitor security of HIE data exchange. Review system logs and investigate security incidents, etc.
$60,846
1
DP Analyst /
Planning Specialist IV
Analyzes agency policy and plans for application systems, operating systems, and data processing personnel. Makes recommendations to supervisors and agency management on proposed enhancements to agency policy and plans, with particular attention to potential budgetary impact.
Manage the implementation of the EHR Incentive payments, meaningful use, connection to the HIE, EHR implementation from a technical perspective for the OHCA.
$60,846
Oklahoma Health Care Authority
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October 15, 2010
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3.3
MITA SS-A
This section will describe the process used to update the Oklahoma MITA SS-A and the business areas, capabilities and technology improvements that result.
The Oklahoma MITA SS-A updates are required due to the additional responsibilities to administer the EHR Provider Incentive Program. The OHCA used a process similar to the process used to develop the original MITA SS-A. Subject matter experts were consulted regarding the business processes needed to support the EHR Provider Incentive Payment Program. These processes were compared to the MITA Business Processes and refined as needed to reflect the work patterns applied in Oklahoma. The result of this assessment was that most business processes would not be impacted by the new program. As a result, the MITA capabilities and maturity levels were not changed.
The MITA assessment did, however, identify several system updates that have occurred since the MITA SS-A was conducted in 2009, resulting in a small number of both capability and maturity level changes to the original MITA SS-A, and those changes are reflected within this MITA SS-A update. In addition, two new business processes were added reflecting the need to implement EHR Incentive Payment provider attestations and provider communication coordination with the Regional Extension Center (REC).
In addition, the OHCA has recently completed the implementation of a web-based Electronic Provider Enrollment (EPE) system. The system extends the ability to providers to manage their own enrollment and demographic information online. This online system will be further enhanced to collect and store the Oklahoma EHR Provider Incentive Payment Program attestation information. Oklahoma Health Care Authority
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3.3.1
Executive Goals and Objectives
This section will describe the high level visioning activities and updates needed to align the MITA SS-A with the HIE, HIT efforts and the EHR Incentive Payment program.
Table 2 Executive Guiding Principles and Objectives
MITA Goal
OK Guiding Principle
Objective/Actions
Integrated Call Center – This will provide enhanced call routing capabilities and the integration and availability of call center data to provide operational efficiency and flexibility across all the OHCA call centers.
Promote efficient and effective data sharing to meet stakeholder needs.
Document Management – Integration of the COLD imaging system with the MMIS for improved access to information and operational efficiency.
Letter Generation – Implement a flexible and configurable system component to improve operational efficiency and enhance member and provider communication.
Enhance and introduce up-to-date management information and communication systems through the MMIS Reprocurement project.
Medical Care Management (Atlantes) – Enhancement of the Atlantes Case Management system and further integration with the MMIS will allow a broader spectrum of the OHCA staff to utilize the system more effectively.
Promote reusable components and modularity.
Claims Processing – Implementation and integration of the existing Business Rules Engine into the MMIS for enhanced claims processing.
Secure Provider Portal – This enhancement will allow providers real-time online access to view and change their account information, saving the OHCA significant staff time in data entry and phone inquiries.
Provider attestation and EHR Incentive Payment Program Participation will be captured using the portal as well.
Integration and Interoperability
Promote efficient and effective data sharing to meet stakeholder needs.
General System Functionality – Enhancement of Data Warehouse capabilities (Data Cubes) for analyzing and reporting of data. It will also include the creation of Dashboards for management decision-making and access to data by the public.
Drug Rebate – Automate the process and provide online access for invoices and payments to suppliers.
Integration and Interoperability
Promote efficient and effective data sharing to meet stakeholder needs.
Drug Utilization Review – Reference data file enhancement. Oklahoma Health Care Authority
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MITA Goal OK Guiding Principle Objective/Actions
Asset Verification – Electronic data exchange with financial institutions for asset verification of Dual Eligible’s.
Provide a beneficiary-centric focus.
Online Enrollment – Implement an online enrollment and eligibility system that will integrate with the MMIS to provide enhanced accessibility and eligibility and benefit determination for members.
Oklahoma Health Information Organization – Through participation in this statewide initiative, the OHCA commits to promote a comprehensive approach to accelerating the exchange of health information by involving providers and consumers, establishing State agency trust, developing sustainable funding sources, providing capable business services and operations, developing technical capabilities and consulting with State officials.
Identify, qualify, and manage a cost-effective, efficient, and flexible SoonerCare program.
Online Enrollment – Implement an online enrollment and eligibility system that will integrate with the MMIS to provide flexibility in response to SoonerCare program and policy changes.
Adopt data and industry standards.
HIPAA 5010 and ICD-10 – The system enhancements to comply with these federally mandated data formats will be included in the MMIS Reprocurement project.
Support integration of clinical and administrative data.
Medical Artificial Intelligence (MEDai) Health Management – The integration of MEDai with the SoonerCare Secure Site will allow providers access to information about the illness burden of the SoonerCare members they treat. This information is critical to providers at the point of care to improve health outcomes for SoonerCare members.
Flexibility to respond rapidly to change
Promote secure data exchange.
Health Information Exchange (HIE) – Implementation of the initial infrastructure to provide the capability to exchange health information between State entities and the public.
Secure Member Portal – Implement a portal to provide members the ability to view and manage their information and eventually the capability for Personal Health Records.
Flexibility to respond rapidly to change
Promote secure data exchange.
Electronic Provider Referral – Online access to information for providers to refer members to a specialist. Oklahoma Health Care Authority
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MITA Goal OK Guiding Principle Objective/Actions
Program Integrity (PI) – The PI system will integrate new technologies with fraud detection and case tracking systems to improve the effectiveness and efficiency of fraud and abuse investigations.
Sustain and maximize available funds.
Medical Policy Review – Review of reimbursement rates and methodologies to ensure that provider payments are consistent with efficiency, economy, and quality of care.
Claims Resolution – Implementation of automated workflow for MMIS claims resolution.
Simplify the claim process, through collaboration with providers.
Claims Processing – Implementation and integration of the Business Rules Engine into the MMIS to provide efficiency and flexibility in the processing of claims.
Enterprise view to align technology and business needs
Break down artificial boundaries between systems, geography, and funding.
Insure OK and Insure Tulsa – Expansion of the Insure Oklahoma premium assistance program to provide insurance coverage for the uninsured.
Insure Oklahoma (IO) – Expansion of the Insure Oklahoma premium assistance program to provide insurance coverage for the uninsured.
Seek to greatly improve the status of health care across the State.
SoonerCare – Expansion of the SoonerCare program for 19- and 20-year olds.
Data that supports analysis and decision-making
Ensure accuracy and correctness of payments.
Program Integrity (PI) – Implement a comprehensive PI system consisting of a Fraud and Abuse Component, a Medical SURS Component, a Case Tracking System, and Data Management for the OHCA Program Integrity & Accountability Unit.
The Insure Oklahoma premium assistance system enhancement will include an electronic management system for financial transactions to and from multiple sources, such as premium receipts, invoices, accounts receivable, accounts payable, state and federal donations, and commissions.
Medical Policy – Review and implementation of enhanced edit and audit functions for MMIS claims processing.
Data that supports analysis and decision-making
Ensure accuracy and correctness of payments.
Finance – Enhancements to the Financial system for management of payments and adjustments and reporting, including provider incentive payments. Oklahoma Health Care Authority
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MITA Goal OK Guiding Principle Objective/Actions
Improve the effectiveness and efficiency of the delivery of medical services.
The Emergency Room (ER) Diversion Grant will help the OHCA develop a program to access a full array of primary and preventative health care for Oklahoma County SoonerCare members. Specifically, this project addresses the overuse of hospital emergency room use.
Maximize revenue by containing costs, eliminating duplication, and using all sources of funds.
The OHCA plans to explore the opportunities that exist to better serve Oklahoma’s Dual Eligible population and to capitalize on the expertise of other states, as well as utilize other resources such as the Center for Health Care Strategies, that might assist the OHCA to develop a care coordination plan for Oklahoma’s Dual Eligibles.
Performance measurement for accountability and planning
Provide continuous improvement/utilization review by evaluating service outcomes, program costs, and provider participation to maximize and effectively manage resources.
Plans to review and make recommendations and/or implement changes in payment methodologies and reimbursements in order to ensure fair compensation to providers.
Coordinate with Public Health and other partners to improve overall health
Attract and maintain a strong network of service providers by continuously evaluating and implementing programs that strengthen the reimbursement process.
Self-Directed Services – The Opportunities for Living Life (OLL) action plans continue to describe the OHCA’s many partnerships with other agencies, providers, and advocates to develop partnerships to improve access to long-term support services, and provide for better choice and control for the OHCA’s aging population.
Coordinate with Public Health and other partners to improve overall health
The OHCA is committed to developing a health care partnership with policy makers, beneficiaries, providers, and stakeholders from the community to provide maximum health care benefits to qualified individuals through innovative and cost-effective programs.
Research in the Health Care Infrastructure in local communities within the State of Oklahoma is intended to allow various stakeholders including, but not limited to local community leaders, etc., to see both the small- and large-scale pictures of the existing health care infrastructure within their communities. It is hoped that this research may help community leaders make informed decisions about future planning. It is expected that at the conclusion of the research a final report will be prepared and distributed to stakeholders across the State. Oklahoma Health Care Authority
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MITA Goal OK Guiding Principle Objective/Actions
The OHCA has implemented a system called the Health Management Program (HMP) that targets members with chronic conditions who have been identified by predictive modeling to have a high risk of incurring significant medical cost.
The HMP provides patient education and care management services to participants. The HMP also develops provider collaboration focused on holistic health management and evidence-based guidelines, and one-on-one practice facilitation for some primary care providers provided by the OHCA’s contractor, the Iowa Foundation for Medical Care.
3.3.2
Needs Relating to State Self-Assessment
This section will describe the business areas impacted by the EHR Incentive Payment Program Implementation and Administration.
In accordance with 42 CFR §495.338 outlining the submission of IAPD documents to CMS for consideration, the OHCA conducted a review of the MITA SS-A previously developed in June 2009 and submitted with the IAPD and RFP on April 1, 2010.
The findings of this review are identified in this section and presented in detail in Appendix C.
Member Management – The Member Management business area is a collection of business processes involved in communication between the Medicaid agency and the prospective or enrolled member and actions that the agency takes on behalf of the member. The goal for this business area is to improve healthcare outcomes and raise the level of consumer satisfaction.
Opportunities will develop as the OKHIE is put into place and eligible providers implement certified EHR technology to improve member management business processes and exchange of individual patient clinical data for treatment, payment, and health plan operations. Through compliance with meaningful use objectives, members will realize improved access to their health care information. Through ePrescribe capabilities, providers will submit prescriptions to pharmacies, allowing members more timely access to necessary medications.
Provider Management – MITA defines the Provider Management business area as a collection of seven business processes that focus on recruiting potential providers, supporting the needs of the provider population, maintaining information on the provider, and communicating with the provider community. The goal of this business area is to maintain a robust provider network that meets the needs of both the member and provider communities and allows the State Medicaid agency to monitor and reward provider performance and improve health care outcomes.
Improvements in Provider Management business processes include online enrollment in the Oklahoma EHR Provider Incentive Payment Program (including online attestation, electronic signature), and allowing providers to self-manage demographic and participation information. In addition, as the OKHIE and the Meaningful Use data store are developed, providers will be able to report Meaningful Use measures and have access to clinical information that will improve outcomes and decision-making for their patients. A collaborative approach continues to inform eligible professionals about the Oklahoma Provider Incentive Payment Program and ongoing communications and collaboration with stakeholders (e.g., HIE, OSMA, OHA, FQHCs/RHCs, I/T/U). Oklahoma Health Care Authority
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Contractor Management – The Contractor Management business area accommodates states that have managed care contracts or a variety of outsourced contracts. The Contractor Management business area has a common focus (e.g., manage outsourced contracts), owns and uses a specific set of data (e.g., information about the contractor or the contract), and uses business processes that have a common purpose (e.g., solicitation, procurement, award, monitoring, management, and closeout of a variety of contract types).
The OHCA has no managed care contracts; thus, there are no needs identified at this time.
Operations Management – The Operations Management business area includes operations that support the adjudication of claims and encounters, payments to providers, other agencies, insurers, Medicare premiums, and support the receipt of payments from other insurers, providers, and member premiums. This business area focuses on adjudication of claims and encounters, payments, and receivables and “owns” all information associated with service payment and receivables.
The OHCA will use their standard MITA business processes for making provider incentive payments, Federal Financial Participation (FFP) drawdown, and recoupment of any payment found to be in error.
Program Management – The Program Management business area houses the strategic planning, policymaking, monitoring, and oversight activities of the agency. These activities depend heavily on access to timely and accurate data and the use of analytical tools. This business area uses a specific set of data (e.g., information about the benefit plans covered, services rendered, expenditures, performance outcomes, and goals and objectives) and contains business processes that have a common purpose (e.g., managing the Medicaid program to achieve the agency’s goals and objectives, such as by meeting budget objectives, improving customer satisfaction, and improving quality and health outcomes).
The OHCA will be developing program policy for the Oklahoma EHR Provider Incentive Program. MMIS enhancements are required to perform accounting functions, support generation of payments, FFP drawdown, and develop new CMS reports required for tracking and reporting on American Recovery and Reinvestment Act (ARRA) funds expended. As OKHIE determines its plans for the future, opportunities will develop to monitor meaningful use measures and provider performance outcomes.
Business Relationship Management – Business Relationship Management refers to the standards for interoperability between the State Medicaid agency and its partners. It contains business processes that have a common purpose (e.g., establish the interagency service agreement, identify the types of information to be exchanged, identify security and privacy requirements, define communication protocol, and oversee the transfer of information).
The OHCA plans to implement contract changes to data exchange agreements with other states; revise trading partner agreements to ensure security and privacy of data exchanged through the statewide HIE, and require exchange of laboratory data for Public Health statewide initiatives.
Program Integrity Management – The Program Integrity business area incorporates those business activities that focus on program compliance (e.g., auditing and tracking medical Oklahoma Health Care Authority
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necessity and appropriateness of care and quality of care, fraud and abuse, erroneous payments, and administrative abuses).
The OHCA will use their standard MITA business processes for auditing and tracking provider incentive payments. There will be availability of clinical data and an increased ability to measure health outcomes and compare between providers best practices for treatment of specific diagnoses. Care Management will be enhanced by the availability of clinical measurement data. The OHCA will leverage the capabilities provided by the planned OKHIE in conjunction with the State system capabilities to review benchmarks and objectives to enhance the administration of the Medicaid program and improve health care delivery and outcomes in Oklahoma.
Care Management – Care Management collects information about the needs of the individual member, plan of treatment, targeted outcomes, and the individual’s health status. It also contains business processes that have a common purpose (e.g., identify clients with special needs, assess needs, develop treatment plan, monitor and manage the plan, and report outcomes).
The OHCA will leverage the clinical data available through the HIE for use in prior authorization and Health Management Program (HMP) programs to better ensure most effective delivery of services at time of need and to control costs and eliminate duplicate services. Availability of clinical data and meaningful use measures will assist in managing population health for those enrolled in OHCA programs.
Oklahoma Specific Business Processes – The MITA framework documents the basic business processes that most Medicaid Enterprises perform. In addition, it allows States to identify processes that are unique to that State. During the Provider Incentive Program Planning Phase MITA assessment, two unique business processes were identified as follows:
1.
Receive and Validate Provider Registration, Enrollment, and Attestation.
2.
Manage Regional Extension Center Referral and Coordination.
Oklahoma Health Care Authority
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4
NATURE AND SCOPE
This section will describe the activities that are covered in the IAPD funding request, and how resources will be acquired to satisfy the needs described in Section 3.3.2 above.
4.1
Planning
This section will describe the overall plan (references to SMHP would be appropriate) to implement the EHR Incentive payment program.
The OHCA will use the business processes described in the SMHP Section 4 to administer the Oklahoma EHR Provider Incentive Payment Program and distribute payments to eligible providers. The EHR Incentive Payment Program reporting to CMS will utilize existing business processes and established infrastructure to comply with all required reporting requirements. Any new reporting requirements by CMS will be incorporated into the existing reporting responsibilities.
4.1.1
System Modification Requirements
This section will include a list of the MMIS system modifications.
MMIS System modifications are described in the SMHP Section 5.1.2.3.3 Anticipated MMIS Modifications. The OHCA plans to complete these changes prior to January 2011 to support the Oklahoma EHR Incentive Payment Program. The OHCA will work with the MMIS support vendor to complete requirements definitions for each modification. These requirements will be based on understanding of the Final Rule, business processes developed to implement the program, and discussions with the MMIS support vendor.
A complete list of the HIT EHR Incentive Payments system changes, including the development time estimates from the MMIS support vendor, are shown by Change Order (CO) in Table 3 below.
Table 3 System Modification under Umbrella CO 10557
CO Number
Subsystem
CO Description
Remarks
Estimated Hours
10557
System Wide
EHR Incentive Payments
Project management
200
10221
Provider Data Maintenance
Provider Incentive Payment
provider online web screen
iCE portion
WF
COLD/RRI
533
250
300
60
10223
Financial
Incentive Payment for Providers
Finance batch
Finance iCE portion
630
250
10331
MAR
EHR Incentive payments - MAR
MAR Modifications
80
10333
Provider Data Maintenance
EHR Incent Paymts-NLR Interface
Interface with NLR
890
Total Estimated Hours
3,193
Oklahoma Health Care Authority
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4.1.2.2 Provider Outreach and Education Plans
A description for HIT Outreach and Education is included in Section 4.2 Communication Plan of
To achieve participation, the OHCA has completed or will complete the following activities:
 Obtain input via various methods/forums:
d a survey of eligible providers to determine
e
4.1.1.1
Develop and Implement System Changes
This section will describe the approach to system development and will include a description of the responsibilities for development.
The EHR Provider Incentive Program system enhancements will follow the same design, development, and implementation (DDI) approach and standards processes established for MMIS system change requests (SCR). The Provider Incentive Program SCRs have been prioritized by the OHCA for implementation to meet the January 2011 program start date. The current MMIS support vendor, Hewlett-Packard (HP), will be responsible for design, development, testing, and implementation of the EPE system changes as well as interfaces between EPE and the National Level Repository (NLR). The OHCA personnel will participate in user acceptance testing (UAT) activities and review all test results.
4.1.2
Operations
The OHCA plans to fully integrate the EHR Incentive Payment Program administration within day-to-day OHCA operations. An organizational chart is provided in the SMHP Section 4.1.10 Concept of Operations.
4.1.2.1
Communication
During the implementation phase, a procedure manual will be developed to communicate all facets of the Oklahoma EHR Provider Incentive Payment Program including eligibility, attestation, payment, recoupment, and provider appeals.
The Outreach, Education, and Information (OEI) work group is responsible for developing a planned approach for internal and external communications to ensure all stakeholders are adequately informed on progress made toward the implementation of the Oklahoma EHR Provider Incentive Payment Program. The OEI work group is responsible for all aspects of information sharing and works closely with all other work groups to ensure that appropriate information is shared, and that it is shared in a consistent manner.
The OEI work group has developed a Communications Plan for informing providers, the public, external agencies, and the media on progress made toward implementation of the Oklahoma EHR Provider Incentive Payment Program, and for sharing communications internally within the OHCA.
the SMHP. Additionally, detailed efforts planned within the next five months prior to program implementation include the efforts described below.
o
S
urveys – the OHCA has conducte
the current status of the provider’s EHR systems and at what level they anticipatachieving electronic health records in the near future. The survey also presented Oklahoma Health Care Authority
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an opportunity to make available information about the EHR Incentive Payment Program to providers.
o
Web input forms – Forms to collect various EHR-related bits of information will be available on the OHCA public web site under the Oklahoma EHR Provider Incentive Payment Program section.
o
Direct contact such as Training events – OHCA Provider Services and the contracted fiscal agent, HP, will train EPs and EHs. Fall 2010 training sessions already scheduled are listed below.
Sept 21, 2010 Sept 29, 30, 2010
Kiamichi Technical Center OSU - Tulsa Conference Auditorium
810 Waldron Road 700 N. Greenwood Avenue
Durant, OK Tulsa, OK
Oct. 14, 2010 Oct 26, 27, 2010
Great Plains Technology Center Moore Norman Technology Center
4500 SW Lee Boulevard South Penn Campus Conference Center
Lawton, OK 13301 S. Pennsylvania
Oklahoma City, OK
o
Telephone calls and follow-ups – Telephone contacts and follow-ups to surveys and other input will be completed by the OHCA Provider Services, contracted partners FOX and HP, and the EHR Planning, Development, and Implementation workgroup.
o
Public hearings – The OHCA is working with the Oklahoma State Department of Public Health to facilitate public hearings to gather input regarding the use of meaningful use outcomes and metrics in Oklahoma.
o
Meetings with professional health organizations, etc. – the OHCA will have ongoing meetings involving health organizations and other interested stakeholders, as there is new information or developments/benchmarks requiring further communication.

Conduct activities geared toward educating eligible professionals (EPs) and eligible hospitals(EHs). The OHCA will develop and maintain information regarding electronic health records to be used to educate providers. Educational activities will include:
o
Face-to-face training events
o
Multimedia presentations
o
Clear-cut messages via our secure provider web site
o
Informative e-mails and optional Internet web alerts
o
Pitching the importance of electronic health information to state health writers and media
o
Providing articles and news releases

News releases about electronic health records can be useful, especially in the rural newspapers. Also, articles written for specialized audiences, Oklahoma Health Care Authority
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4.1.2.5 Provider Payments
A detailed description for Provider Payment is included in the SMHP Section 4.6 Processing of
4.1.2.6 Provider Payment Monitoring
in Section 4.6.3 Provider Payment Monitoring.
n 4.7 Reporting Requirements.
such as eligible professionals and eligible hospitals, are an indirect means of reaching target audiences
o
Partnering with various agencies, related work groups, and professional health organizations
o
Partnering with other interested parties, which provides a means for additional contact with potentially eligible professionals and eligible hospitals, as well as members/consumers, and an opportunity to educate them about electronic health records
o
Directly contacting EPs and EHs via letters and phone calls. Contacting EPs and EHs is a great opportunity to educate them as well as get input.
o
Utilizing the web site and social media to share information. According to various sources, non-traditional media is an important source of health information, especially among the younger generations.
4.1.2.3
Provider Eligibility and Enrollment in EHR Incentive Payment Program
A detailed description for HIT Provider Eligibility and Enrollment is included in the SMHP Section 4.5 Provider Eligibility for Incentive Payments.
4.1.2.4
Provider Attestation
A detailed description for HIT Environment Registration and Attestation is included in the SMHP Section 3.2 Vision for HIT Environment.
Payments to Providers.
A detail
ed description is included in the SMHP
4.1.2.7 EHR Incentive Payment Reporting
A detail
ed description is included in the SMHP Sectio
Oklahoma Health Care Authority
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5
STATEMENT OF ALTERNATIVE CONSIDERATIONS
5.1
Description of Alternatives
This section describes any alternative analysis that was conducted, or state why none was necessary.
The OHCA considered one alternative to implementation of the EHR Provider Incentive Program as follows:
Alternative 1: Take no Action
1.
If the OHCA did not request the EHR Incentive Payment Administration FFP: The OHCA would not be in a position to implement MMIS modifications to receive electronic attestations nor validate provider registration in the NLR.
2.
The OHCA is not in a position to fund 100 percent of the positions required to support the Provider Incentive program from an administrative perspective.
3.
The OHCA could not produce required federal reporting or complete the required audit functions without federal funding.
No other alternatives were considered given the relative ability of the Oklahoma MMIS to allow providers to have secure access to the EPE system, process provider supplemental payments, as well as capture certain accounting and reporting requirements. The Oklahoma MMIS is the technical solution that most closely matches the business needs to support the EHR Provider Incentive Payment Program. Oklahoma Health Care Authority
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6
STATE RESOURCES
6.1
Medicaid Structure
In Oklahoma, the OHCA has the responsibility of administering the State’s Medicaid program. Created in 1993 by legislative authorization, the Designated Single State Medicaid Agency was transferred from the Department of Human Services to the OHCA, effective January 1, 1995. The agency’s mission “is to purchase state and federally funded health care in the most efficient and comprehensive manner possible, and to study and recommend strategies for containing costs and optimizing the accessibility and quality of health care.”
The agency must balance fiscal responsibility with two equally important goals:
1.
Assure that State-purchased health care meets acceptable standards of care.
2.
Ensure that citizens of Oklahoma who rely on State-purchased health care are served in a progressive and positive system.
6.2
OHCA Administration
The OHCA is governed by the Health Care Authority Board. Mr. Michael Fogarty is the current Chief Executive Officer of the Authority. The OHCA contains five operational areas and three administrative support groups. The eight major areas of the Authority are:
SoonerCare Operations:

Medical Professional Services

SoonerCare Program Operations & Benefits

Care Management

Medical Authorization Services

Insure Oklahoma

SoonerCare Provider Services

SoonerCare Member Services

SoonerCare Health Benefits Support

SoonerCare Quality Assurance/Quality Improvement

Opportunities for Living Life
o
Level of Care Evaluations
o
Long Term Care Quality Initiatives
o
Waiver Administration
Information Services:

Health Information Infrastructure Advisory Board

Contractor Systems Oklahoma Health Care Authority
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
Eligibility Automation and Data Integrity

Infrastructure Software and Support

Network Operations & Design

Database Administration

Application Development
Financial Services:

Provider Rates Analysis

Budget & Fiscal Planning

Financial Management

General Accounting

Purchasing

Federal Reporting

Financial Resources

Third Party Liability, Claims Resolution, and Adjustments
Policy, Planning, and Integrity:

Human Resources

Health Policy

Planning & Development

Program Integrity and Accountability

Provider Audits

Waiver Development & Reporting

Performance & Reporting
Legal Services:

Legal Operations

Contracts Development

Provider Contracting
Civil Rights Freedom of Information Act
Administrative Services
External Relations & Communications

Governmental Affairs Oklahoma Health Care Authority
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
Public Affairs

Federal/State Policy on Appropriations

Reporting & Statistics
6.2.1
OHCA Key Staff
Staff from the SoonerCare Program Operations Division and from the Policy, Planning, and Integrity Division will have primary responsibility for managing the project. Staff from the Information Systems Division will be the lead analysis and technical staff. Currently, certain staff members are charged with contract management tasks involved in overseeing development and operations.
Management-level representatives from other OHCA divisions and sections will participate in definition of requirements for the program, systems testing, acceptance testing, and implementation planning.
Key Roles anticipated for the OHCA staff include the following:

Becky Pasternick-Ikard, Deputy State Medicaid Director, project manager

Cindy Roberts, Deputy Chief Executive Officer, policy manager

John Calabro, Chief Information Officer, technical manager

Carrie Evans, Chief Financial Officer, financial manager
6.3
Administrative Costs
Additional State personnel resource needs are described in Section 3.2 Needs of this document. In addition, the OHCA plans provider outreach, training and travel related to the administration of the program. These costs are outlined in the table below
Table 4 Estimated Costs to Administer EHR Provider Incentive Payment Program
FFY 2011
FFY 2012
Cost Description
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Total
Enhanced Federal Funds 90% Participation
State Operational Staff
$152,798.63
$219,344.82
$219,344.82
$219,344.82
$219,344.82
$219,344.82
$219,344.82
$219,344.82
$1,688,212.34
Training & Outreach
11,250.00
38,250.00
11,250.00
11,250.00
11,250.00
11,250.00
11,250.00
11,250.00
117,000.00
Travel
4,500.00
4,500.00
4,500.00
4,500.00
4,500.00
4,500.00
4,500.00
4,500.00
36,000.00
Total Admin Enhanced FFP
$168,548.63
$262,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$1,841,212.34
OHCA Share Funding 10%
State Operational Staff
$16,977.63
$24,371.65
$24,371.65
$24,371.65
$24,371.65
$24,371.65
$24,371.65
$24,371.65
$187,579.15
Training & Outreach
1,250.00
4,250.00
1,250.00
1,250.00
1,250.00
1,250.00
1,250.00
1,250.00
13,000.00
Travel
500.00
500.00
500.00
500.00
500.00
500.00
500.00
500.00
4,000.00
Total OHCA Share Fdi
$18,727.63
$29,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$204,579.15
Total FFP and OHCA
$187,276.25
$291,216.46
$261,216.46
$261,216.46
$261,216.46
$261,216.46
$261,216.46
$261,216.46
$2,045,791.49
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7
SCOPE OF ACTIVITIES AND PROJECT METHODOLOGY
7.1
Project Approach
This section will describe the overall approach to the implementation of the Incentive Payment Program. Describe the manner in which the tasks are organized.
7.2
Tasks
7.2.1
Tasks Completed to Date
This section will list activities that have been completed in support of the EHR Incentive Payment Program.
The planning tasks completed to date in support of the Oklahoma EHR Provider Incentive Payment Program are listed below:

Contracted with a vendor, FOX, A Cognosante Company, to assist the OHCA in project management, SMHP development, and IAPD development

Obtained project appropriation from the Legislature

Completed the MITA SS-A As Is, To Be, Gap Analysis, and Roadmap

Identified and evaluated future business needs

Identified and evaluated current business needs not met by the current system

Identified and evaluated technological needs

Submitted SMHP to CMS and received approval on Sept. 3,2010
7.2.2
Tasks Underway at This Time

Submit IAPD for CMS approval

Develop Policy and Procedures required to support the Oklahoma EHR Provider Incentive Payment Program
7.2.3
Tasks to Be Undertaken
Implementation Advance Planning Document

Obtain IAPD approval from CMS

Submit revised SMHP to CMS for approval, and annually thereafter

Provide updated IAPD as necessary throughout the implementation and administration of the EHR Provider Incentive Payment Program
EHR Provider Incentive Payment Program Implementation

Obtain SMHP approval from CMS

Submit MMIS modifications to vendor Oklahoma Health Care Authority
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
Establish new policies for the Oklahoma EHR Provider Incentive Payment Program
7.2.4
Activity Schedule for the Project
This section will include a brief description of what is included in the schedule.
Table 5 Proposed Activity Schedule
Activity
Start Date
End Date
PAPD Activities
Project Planning
3/15/2010
Assess Current As Is Landscape
5/28/2010
Create HIT To Be Vision
5/30/2010
Develop Provider Incentive Program
8/13/2010
Update HIT Roadmap
6/30/2010
Develop SMHP
6/30/2010
IAPD
Develop IAPD
7/14/2010
7/31/2010
Submit IAPD to CMS
9/10/2010
CMS IAPD Review and Approval
10/10/2010
EHR Incentive Payment Program Implementation Preparation
MMIS Modifications
7/13/2010
1/7/2010
Test NLR Transactions with CMS
10/15/2010
11/1/2010
OHCA Policy and Procedure Revisions
7/13/2010
11/28/2010
Provider Manual Updates
7/13/2010
11/28/2010
EHR Incentive Payment Program Administration
Implement EHR Provider Incentive Payment Program
1/1/2011
Receive NLR Registration Transactions
1/1/2011
Receive Provider Attestations
1/1/2011
EHR Incentive Payment Program Payment Review & Authorization
1/1/2011
First Provider Incentive Payments
1/31/2011
Coordinate Provider Incentive Plan with stakeholders (e.g., Medicare, I/T/Us, and SHIECAP entities)
Ongoing
Coordinate Provider Incentive Plan with RECs
Ongoing
Identify Meaningful Use data collection requirements
6/30/2011
Identify Meaningful Use data collection solution
TBD
Develop IAPD Update to support data collection solution
TBD
Implement Meaningful Use data collection solution
TBD
A detailed Project Plan is included in Appendix B. Oklahoma Health Care Authority
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8
PROPOSED BUDGET
8.1
Overview
This section will include a description of the budget components.
Oklahoma’s proposed budget describes the costs associated with the administration of the EHR Incentive Payment Program, including:

State staff salaries and benefits to monitor and release payment requests, audit provider attestations, and support provider outreach, education, and inquiries

An estimate of the development costs associated with MMIS system modifications to support the administration of the Oklahoma EHR Provider Incentive Payment Program
The MMIS system modification costs are separated in the tables below from the Program Administration costs in alignment with the federal funding opportunities available from CMS under ARRA Section 4201.
All MMIS and EPE system modifications are listed in detail in the Oklahoma SMHP and are included in the MITA SS-A update and HIT Roadmap.
All cost estimates, methodologies, and allocations are in accordance with Section 11275 of the State Medicaid Manual, Chapter 11. The agreement includes a statement that the State will provide the requisite matching funds available for this project.
8.2
Budget by State and Federal Share
Tables 6 and 7 below identify the split between state and federal funds for each quarter.
Table 6 Estimated Quarterly Costs to Administer Program – Federal
FFY 2011
FFY 2012
Cost Description
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Total
Enhanced Federal Funds 90% Participation
HIT Administrative Costs
HIT In-house Planning
HIT Private Contractor Planning
HIT Implementation and Operation In-house Costs
$168,548.63
$262,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$235,094.82
$1,841,212.34
HIT Implementation and Operation Costs Private Contractor
$211,950.00
$208,350.00
$204,750.00
$168,750.00
$276,750.00
$276,750.00
$276,750.00
$276,750.00
$1,900,800.00
Total Enhanced FFP
$380,498.63
$470,444.82
$439,844.82
$403,844.82
$511,844.82
$511,844.82
$511,844.82
$511,844.82
$3,742,012.34
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Table 7 Estimated Quarterly Costs to Administer Program – State
FFY 2011
FFY 2012
Cost Descriptions
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Oct-Dec
Jan-Mar
Apr-Jun
July-Sept
Total
OHCA Share Funding 10%
HIT Administrative Costs
HIT In-house Planning
HIT Private Contractor Planning
HIT Implementation and Operation In-house Costs
$18,727.63
$29,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$26,121.65
$204,579.15
HIT Implementation and Operation Costs Private Contractor
$23,550.00
$23,150.00
$22,750.00
$18,750.00
$30,750.00
$30,750.00
$30,750.00
$30,750.00
$211,200.00
Total OHCA Share Funding
$42,277.63
$52,271.65
$48,871.65
$44,871.65
$56,871.65
$56,871.65
$56,871.65
$56,871.65
$415,779.15
*Total FFP and OHCA
$422,776.25
$522,716.46
$488,716.46
$448,716.46
$568,716.46
$568,716.46
$568,716.46
$568,716.46
$4,157,791.49
*Total Tables 6 and 7
Assumptions:
1.
The OHCA State Personnel will need to be available to administer the program beginning in January 2011.
2.
Tables 6 and 7 above include cost estimates for State and Contractor Personnel in 4th Quarter 2010, and estimated costs to implement and administer incentive payments during the first two FFYs of the program.
3.
As required by the Final Rule, costs shown by FFY and Quarter include: contractor cost to conduct requirements gathering for meaningful use Data Warehouse and bridge to integrate MMIS to OKHIE and develop resulting RFP and IAPDs; equipment and supplies; training and outreach; travel; personnel for administrative operations, and administrative expenses (e.g., costs for hardware and software DDI for MMIS and EPE systems as described in Section 4.1.1 of this IAPD).
4.
Report estimated costs in IAPD per CMS 64 reporting formats to allow alignment of estimated to actual costs. Oklahoma Health Care Authority
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Combined Incentive Payments
Calendar Year
Table 8 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by Calendar Year
CY 2011
CY 2012
CY 2013
CY 2014
CY 2015
CY 2016
CY 2017
CY 2018
CY 2019
CY 2020
CY 2021
CY 2022
Total
EP
$30,812,500
$25,075,000
$23,800,000
$22,100,000
$22,950,000
$26,987,500
$11,475,000
$6,375,000
$3,825,000
$2,975,000
$2,125,000
$178,500,000
EH
$17,438,798
$43,015,703
$35,458,890
$15,694,919
$4,069,053
$581,293
$116,258,656
TOTAL
$48,251,298
$68,090,703
$59,258,890
$37,794,919
$27,019,053
$27,568,793
$11,475,000
$6,375,000
$3,825,000
$2,975,000
$2,125,000
$294,758,656
Combined Incentive Payments
State Fiscal Year
Table 9 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by State Fiscal Year
SFY 2011
SFY 2012
SFY 2013
SFY 2014
SFY 2015
SFY 2016
SFY 2017
SFY 2018
SFY 2019
SFY 2020
SFY 2021
SFY 2022
Total
EP
$15,406,250
$27,943,750
$24,437,500
$22,950,000
$22,525,000
$24,968,750
$19,231,250
$8,925,000
$5,100,000
$3,400,000
$2,550,000
$1,062,500
$178,500,000
EH
$8,719,399
$30,227,251
$39,237,296
$25,576,904
$9,881,986
$2,325,173
$290,647
$116,258,656
TOTAL
$24,125,649
$58,171,001
$63,674,796
$48,526,904
$32,406,986
$27,293,923
$19,521,897
$8,925,000
$5,100,000
$3,400,000
$2,550,000
$1,062,500
$294,758,656
* SFY 2011 is two quarters
Combined Incentive Payments
Federal Fiscal Year
Table 10 Estimated Incentive Payments to Eligible Professionals and Eligible Hospitals by Federal Fiscal Year
FFY 2011
FFY 2012
FFY 2013
FFY 2014
FFY 2015
FFY 2016
FFY 2017
FFY 2018
FFY 2019
FFY 2020
FFY 2021
FFY 2022
Total
EP
$23,109,375
$26,509,375
$24,118,750
$22,525,000
$22,737,500
$25,978,125
$15,353,125
$7,650,000
$4,462,500
$3,187,500
$2,337,500
$531,250
$178,500,000
EH
$13,079,099
$36,621,477
$37,348,093
$20,635,911
$6,975,519
$1,453,233
$145,323
$116,258,656
TOTAL
$36,188,474
$63,130,852
$61,466,843
$43,160,911
$29,713,019
$27,431,358
$15,498,448
$7,650,000
$4,462,500
$3,187,500
$2,337,500
$531,250
$294,758,656
* FFY 2011 is three quarters Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 33
Assumptions:
1.
The program will begin in January 2011 and will therefore include only three quarters in FFY 2011, two quarters in SFY 2011.
2.
The program will sunset in December 2021.
3.
Anticipated EP EHR adoption rates are based on information gathered in an environmental scan conducted by the OHCA in May-June 2010 to understand a baseline rate of EHR usage among Medicaid providers. This environmental scan, while providing useful information regarding the interest in and use of EHR is not considered a research-based, nor statistically sound survey instrument.
4.
The SoonerCare program engages over 29,452 unduplicated providers; an estimated 6,349 are providers of the types eligible for the Incentive payments program. Forty-seven percent (47%) have reported usage of EHRs and 88 percent responding to the Environmental Scan planned participation in the program. There are 2,800 (approximately 50% of those planning participation) providers that are estimated to be eligible and receive Medicaid Incentive payments over the course of the program period.
5.
The OHCA has collaborated with the Oklahoma Hospital Association (OHA) to understand the rates of adoption and estimated incentive payment amounts for eligible hospitals in Oklahoma.
6.
The OHCA plans to disseminate payments to eligible hospitals over a three year period from the point that the hospital becomes eligible. Hospitals will receive 50 percent of their payment in the first year, 40 percent in the second year, and 10 percent in the third year. This payment structure is most favorable to encourage adoption by small, rural hospitals and ensures rapid incorporation of EHR systems in their facilities.
7.
The hospital growth factor applied is 1.33 percent annually.
8.
The estimates do not include potential eligible providers based outside of Oklahoma.
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 34
9
STATEMENTS OF ASSURANCES
The OHCA makes the following assurances in regards to this request for enhanced federal funding for the implementation and administration of the Oklahoma EHR Incentive Payment Program, including system modifications necessary to support the program.
The OHCA agrees with the following:

The system meets the system requirements and performance standards in Part 11 of the State Medicaid Manual (SMM).

The MMIS will support the data requirements of the Peer Review Organizations established under Part B of Title XI of the Social Security Act.

The OHCA has a royalty-free, non-exclusive, and irrevocable license to reproduce, publish, or otherwise use and authorize others to use for federal government purposes, software, modifications to software, and documentation that is designed, developed, installed or enhanced with 90 percent FFP.

The costs of the system will be determined in accordance with OMB Circular Number A-87 as referenced in 45 CFR 74.171.

The State of Oklahoma will provide the requisite matching State funds for the costs of this project.

The pertinent requirements of 45 CFR 95.612 on disallowance and of 45 CFR 95.621 on system security applies.

The contracts involving a fiscal agent (FA) will specify the contract conditions are firm and fixed during the life of the contract, and specify the pricing and conditions for changing the contract.

The contract must include a clause permitting cancellation of the contract within a specified time period if the FA is found out of compliance with the contract’s terms.
The request for 90 percent FFP is in accordance with the requirements at 42 CFR 433.112(5) and (6). The State of Oklahoma will include in the contract for services related to this IAPD the following requirements:

The OHCA will own any software that is designed, developed, installed, or improved with 90 percent FFP.

The U.S. Department of Health and Human Services (DHHS) has a royalty-free, non-exclusive, and irrevocable license to reproduce, publish, or otherwise use and authorize others to use, for Federal government purposes, software, modifications to software and documentation that is designed, developed, installed, or enhanced with 90 percent FFP.

The OHCA will assure that adequate security and privacy are maintained in the MMIS:
o
Security Requirements – The OHCA will ensure that information in the system will be safeguarded in accordance with Subpart F, Part 431 of 42CFR; and 45 CFR 164 Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 35
o
Security and Contingency Plan

The OHCA may elect to perform annual security reviews of the contractor operations to ensure that the information contained in the MMIS will be properly safeguarded. Security standards used in the review will be based on industry standards and contain the components required under 42 CFR 95.621, Subpart (f) and 45 CFR 74 Subpart P.

The FA will be required to provide a contingency plan that includes measures to protect the MMIS data from errors or disasters, as well as procedures for error and disaster recovery, including an adequate back-up processing site. The OHCA will review the FA's security and contingency plan annually and request updates as necessary.
o
Interface Certification – The Work Order issued as a result of the approved IAPD will require the MMIS and all interfaces to be designed and conform to the requirements of Subpart F, Part 431 of 42CFR and the final security and 45 CFR 164. Once implemented, the OHCA will assure the MMIS and all interfaces are operated in compliance with these regulations. The Work Order will also require delivery of detailed plans for disaster recovery procedures and continuity of operations.
o
Disaster Recovery Procedure – The MMIS FA will be required to develop and maintain a Business Continuity Plan that addresses all aspects of disaster recovery for the MMIS. The business continuity plan will provide procedures for system restoration for emergencies and disasters, and for maintaining a state of readiness to meet the operational requirements of the MMIS. It will include a Disaster Recovery Plan.

The system must be compatible with the claims processing and information retrieval systems used in the administration of Medicare for prompt eligibility verification and for processing claims for persons eligible for both programs

The system must support the data requirements of quality improvement organizations established under Part B of title XI of the Act

The actual costs of the system will be determined in accordance with 45 CFR 74.171

The OHCA agrees that the information in the system will be safeguarded in accordance with subpart F, part 431 of this subchapter Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 36
10
CONCLUSION
This section will include the IAPD objectives and the funding request.
The OHCA’s objectives in preparing this IAPD are twofold. One objective in preparing this IAPD is to provide CMS:

A comprehensive description of the needs and objectives

The project scope

The project schedule

The requirements analysis and alternative considerations

The required resources

The proposed budget and cost distribution
The second objective is to request enhanced FFP for the resources needed to administer the Oklahoma EHR Provider Incentive Payment Program and 100 percent funding for Provider Incentive Payments.
The OHCA will be diligent in keeping CMS informed and involved throughout the EHR Provider Incentive Payment Program implementation and all related subsequent activities. The OHCA will seek CMS approval of all documents and activities as required. This document includes all information required by CMS and the appropriate federal regulations. The OHCA has taken great care to ensure this project is:

Well-planned and technically sound, and will be managed effectively

Consistent with CMS’ goals, such as promoting common claim forms and procedure coding, fostering Medicaid provider satisfaction, and meeting HIPAA and CLIA legislation

Cost-effective

Compliant with all federal and state procurement requirements
The State of Oklahoma is requesting CMS approval of this IAPD. The total funding anticipated from ARRA 4201 for this program includes $298,500,668. The breakdown is as follows:

$294.8 million at 100 percent FFP for provider incentive payments through 2021

Enhanced funding at 90 percent for program administration for FFYs 2011 and 2012 of $1,841,212 and federal share in HIT Administrative Costs

$1,900,800 in Contractor costs for FFYs 2011 and 2012

The OHCA will prepare IAPDUs to request program administration funding for the FFY 2013 through 2021 as the costs to administer meaningful use data collection are determined.
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 37
APPENDIX A: ACRONYMS
Acronym
Description
ARRA
American Recovery and Reinvestment Act of 2009
CMS
Centers for Medicare & Medicaid Services
CFR
Code of Federal Regulations
CBA
Cost Benefit Analysis
CHIPRA
Children’s Health Insurance Program Reauthorization Act of 2007
DDI
Design, Development, and Implementation
DW
Data Warehouse
DSS
Decision Support System
EDP
Electronic Data Program
EHR
Electronic Health Record
EHs
Eligible Hospitals
EMR
Electronic Medical Record
EPs
Eligible Professionals
EPE
Electronic Provider Enrollment
ER
Emergency Room
FA
Fiscal Agent
FFP
Federal Financial Participation
FFY
Federal Fiscal Year
FQHCs
Federally Qualified Health Centers
FOX
FOX, A Cognosante Company
GAO
Government Accountability Office
HIE
Health Information Exchange
HIIAB
Health Information Infrastructure Advisory Board
HIT
Health Information Technology
HMP
Health Management Program
HP
Hewlett-Packard
IAPD
Implementation Advance Planning Document
IHS
Indian Health Services
IAPD(s)
Implementation Advanced Planning Document(s)
I/T/U
Indian Health Services / Tribal facilities/Urban Indian Clinics
ITB
Invitation to Bid
IO
Insure Oklahoma
MARS
Management and Administration Reporting System
MEDai
Medical Artificial Intelligence
MITA
Medicaid Information Technology Architecture
MMIS
Medicaid Management Information System
NCPDP
National Council for Prescription Drug Programs Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 38
Acronym Description
NLR
National Level Registry
NPI
National Provider Identifier
OEI
Outreach, Education, and Information
OFMQHIT
Oklahoma Foundation of Medical Quality Health Information Technology
OHA
Oklahoma Hospital Association
OHCA
Oklahoma Health Care Authority
OK
State of Oklahoma
OKHIE
Oklahoma Health Information Exchange
OLL
Opportunities for Living Life
ONC
Office of the National Coordinator for Health Information Technology
OSF
Oklahoma Office of State Finance
OSMA
Oklahoma State Medical Association
OSUCRH
Oklahoma State University Center for Rural Health
P-APD
Planning Advance Planning Document
PI
Program Integrity
REC
Regional Extension Center
RFP
Request for Proposal
RHCs
Rural Health Centers
SCR
System Change Request
SHIECAP
State Health Information Exchange Cooperative Agreement Program
SMHP
State Medicaid Health Information Technology Plan
SMM
State Medicaid Manual
SS-A
State Self-Assessment
SURS
Surveillance Utilization Review System
TIN
Taxpayer Identification Number
Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
APPENDIX B: PROJECT PLAN
Page 39
I Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
Page 40
APPENDIX C: MITA SS-A UPDATE
The table below contains a list of all identified MITA business processes impacted by the Oklahoma EHR Provider Incentive Payment Program. It includes those processes affected by meaningful use requirements as well as those with an opportunity for higher MITA Maturity Capabilities Level. These improvements in the MITA Maturity Level can be achieved if more automated processes are implemented and business process changes are.
MITA BP Number
MITA Business Process Name
Issues and Opportunities
PIP and SMHP
Opportunities for Improvements
Current MITA Maturity Level
New MITA Maturity Level based on IAPD Request
Member Management
ME 01
Determine Eligibility
PIP will need access to determine eligibility information as input to measuring target patient % met for provider Medicaid population.
HIT/HIE provides opportunity for centralized patient index/Master patient index (central patient identity resolution)locator and registry.
Significant opportunity to improve semantic interoperability between state’s eligibility system and MMIS if standard Metadata used.
1
1
ME 02
Enroll Member
HIT/HIE provides opportunity for centralized patient index/Master patient index (central patient identity resolution)locator and registry.
Significant opportunity to improve semantic interoperability between state’s eligibility system and MMIS if standard Metadata used.
1
1
ME 03
Disenroll Member
HIT/HIE provides opportunity for centralized patient index/Master patient index (central patient identity resolution)locator and registry.
Significant opportunity to improve semantic interoperability between state’s eligibility system and MMIS if standard Metadata used.
1
1
ME 04
Inquire Member Eligibility
Member Eligibility supports the health information exchange goals to provide eligibility inquiry capabilities.
Extend the member eligibility inquiry function to HIE participants to validate eligibility real time.
2
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October 15, 2010
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MITA BP Number MITA Business
Process Name
Issues and Opportunities
PIP and SMHP
Opportunities for Improvements Current MITA
Maturity Level
New MITA
Maturity Level
based on IAPD
Request
ME07
Manage Applicant & Member Information
HIT/HIE provides opportunity for centralized patient index/Master patient index (central patient identity resolution) locator and registry.
Significant opportunity to improve semantic interoperability between state’s eligibility system and MMIS if standard Metadata used.
1
1
ME 08
Perform Population and Member Outreach
HIT/HIE provides opportunity for centralized patient index/Master patient index (central patient identity resolution)locator and registry.
Significant opportunity to improve semantic interoperability between state’s eligibility system and MMIS if standard Metadata used.
1
1
Provider Management
PM 01
Enroll Provider
Electronic Provider Enrollment (EPE) is leveraged to capture provider attestation and program enrollment. The provider is able to enroll online, signify attestation and request incentive payment.
Providers could electronically submit attestation documentation.
Notices regarding annual payments, information regarding PIP, MU etc.
1
2
PM 02
Disenroll Provider
Capability to disenroll online is not automated and is entirely a manual process and manual errors may occur. Disenrollment due to sanctions of prescribers is not automated; electronic file is shared throughout the agency. Notification of provider disenrollment, termination or death is manually verified through the licensing board or physician’s office communication is not always timely.
Significant opportunity to improve timeliness of disenrollment and eliminate data entry errors through automated exchange of information.
2
2
PM 04
Manage Provider Communication
EPE allows providers to enroll and electronically submit required documentation. PIP will increase the number of provider communication opportunities.
Consider implementation of contact management solution tied to MMIS.
1
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Implementation Advance Planning Document
October 15, 2010
Page 42
MITA BP Number MITA Business
Process Name
Issues and Opportunities
PIP and SMHP
Opportunities for Improvements Current MITA
Maturity Level
New MITA
Maturity Level
based on IAPD
Request
PM 05
Manage Provider Grievance and Appeal
Providers will have the ability to appeal an eligibility decision based on the patient volume, meaningful use of EHR data, or Adoption, Implementation, Upgrade documentation. In addition, providers will be able to appeal the incentive payment amount.
Provider appeals information could be integrated.
1
1
PM 06
Manage Provider Information
Provides access to records as required by Provider Management Area business processes workflow.
Opportunity for further enhancement to automate upload of provider information from NLR data base.
2
2
PM 07
Perform Provider Outreach
Currently no formal process for assessing impact of provider outreach; no centralized repository for obtaining and coordinating outreach activities and provider visits.
Opportunity for further enhancement to centralize collection and storage of provider communications.
2
2
State Specific
Receive and Validate Provider Registration, Enrollment and Attestation
PIP requires management of information regarding a provider’s annual request and eligibility and registration in PIP. Providers will at a minimum attest that they have a certified EHR, 30% Medicaid patient volume, able to meet meaningful use and has complied with the rules regarding participation.
Further enhancement to allow providers to submit electronic copies of documentation supporting attestation.
NEW
2
State Specific
Manage Regional Extension Center Referral and Coordination
Give providers the REC contact information or forward provider requests to the REC.
Explore opportunities for specific ongoing activities that could be automated, including central storage of referrals and communications with REC.
NEW
1 Oklahoma Health Care Authority
Implementation Advance Planning Document
October 15, 2010
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Business Relationship Management
BR 01
Establish Business Relationship
Establish business relationships process is manual.
1
1
Contractor Management
CO 03
Manage Administrative or Health Services Contracts
The OHCA has modified provider contracts to include a requirement that providers leverage e-prescription opportunities and reporting of lab results.
1
1
CO 06
Manage Contractor Communication
Communication is performed manually. MMIS specific communications for Change Control & Management are not comprehensive and notification sporadic.
Improved communication tracking could lead to better program efficiencies and consistent messaging to stakeholders.
1
2
CO 07
Perform Contractor Outreach
Administration of the PIP requires extensive and ongoing outreach to providers. The SMHP describes the efforts the OHCA intends to apply to engage providers in this opportunity.
Explore opportunities for specific ongoing activities that could be automated.
1
1
Operations Management
OM 10
Prepare Provider EFT Check
Currently 80% providers receive EFTs. Automated check process unless paper check required. RAs and paper checks manually matched.
Opportunity to issue provider incentive payment via EFT.
2
2
OM 18
Inquire Payment Status
PIP will require that providers are able to inquire as to the status of their PIP payment request. The OHCA intends to leverage existing functionality.
2
2
OM 19
Manage Payment Information
PIP will require that incentive payments are managed separately to support Federal reporting requirements.
Explore opportunities for specific ongoing activities that could be automated.
2
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OM 24
Manage Recoupment
PIP requires that provider payments made in error or through fraud be recouped by the SMA. The OHCA intends to leverage existing business processes and functionality when errors or fraud are detected.
Explore opportunities for specific ongoing activities that could be automated.
2
2
Program Management
PG 01
Designate Approved Services/Drug Formulary
Automatic interpretation of NDC file is not working, requiring manual review. System changes required for some codes and not always completed timely. Source for HCPCS/CPT code information is not established and may not be timely.
2
2
PG 05
Develop and Maintain Program Policy
PIP requires that policies are in place that support the Final Rule (INSERT RULE NO) and clarify local decisions regarding the calculation of patient percentage, coordination with border states.
Looking at getting public comment each time a change is going to be made. The proposed changes will be posted with a blog to allow for comments prior to making the change permanent. These changes will be accepted electronically.
Will develop a process to notify stakeholders of all policy related changes. This would include
waivers, state plan, policy, etc.
2
2
PG 12
Generate Financial and Program Analysis/Reports
PIP requires Financial and program analysis and reporting. Reports must segregate the Incentive Payments and Administrative Costs.
2
2
PG 14
Manage Program Information
Program analysis and reporting needs of PIP are managed in DSS.
2
2
PG 15
Perform Accounting Functions
The OHCA utilizes multiple siloed accounting systems. No integration between MARS, DSS, and financial data. Internal account coding and quarterly expenditure coding not aligned.
1
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PG 16
Develop and Manage Performance Measures and Reporting
PIP requires providers to electronically submit the data supporting Meaningful Use Measures. The SMHP describes the Year 1 approach, accepting provider attestations that Meaningful use data collection is occurring.
Meaningful Use (MU) data, measures and objectives stored in a data warehouse will allow the OHCA to automatically determine provider PIP eligibility related to MU. In addition, the SMA will have access to a data source that will provide a basis for measuring programmatic outcomes.
1
1
PG 17
Monitor Performance and Business Activity
No integrated systems to collect and report on performance activities. Lack of access to data from other state agencies and other states. Inability to drill down to detail performance data.
The OHCA plans to implement meaningful use data warehouse under separate chapter to this IAPD.
1
1
Program Integrity Management
PI 01
Identify Candidate Case
The PIP requires audit of the Provider’s EHR data as it supports the meaningful use of this data. It will be necessary to use existing tools to validate the measures and data submitted by the providers to qualify for incentive payments.
In the future additional tools may be used to expand criteria used to complete audits.
It is hoped that further demonstrations from vendors will be presented to help with:
·
Data analysis
·
Algorithms
·
Queries, etc.
The OHCA hopes to gain additional experience and ideas from other state agencies in this area.
1
1
PI 02
Manage Case
Program Integrity unit will need to identify the detailed steps required in the Provider Meaningful use data audit that will be conducted.
1
1
Care Management
CM 01
Establish Case
PIP could provide an opportunity to integrate member cases and EHR to most effectively deliver services and control costs.
Additional integration between the MMIS and the Eligibility systems can enhance the effectiveness of member support.
1
1
CM 02
Manage Case
Begin sending risk scores and diagnosis to the HMP contractor with predictive modeling tool
1
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CM 03
Manage Medicaid Population Health
The PIP through the Meaningful Use requirements will improve the availability of information available to evaluate and manage population health with EHR in addition to claims and PQRI data.
OCHA wants to develop an efficient way to integrate data across the state and have this information put in a centralized location for all to view.
In the future, the OHCA would like to have resources that specialize in analyzing data and implementing strategies as an outcome of analyzing data.
1
1
CM 04
Manage Registry
PIP Meaningful use optional criteria in Year 1 includes the integration of public heath data such as immunization and electronic health surveillance information.
Predictive Modeling System could be used as a Registry.
The Atlantes System has a future version with capabilities for Predictive Modeling.
HMP Providers are entering clinical data in their Registry and that data is not available to the OHCA.
The OHCA would like to integrate this information into the MMIS. (Interfacing HMP data with the
MMIS.)
HIE will need to leverage state-wide assets such as immunization, birth & death registries to support the health reform initiatives.
1
1